Coronado Coal Co. v. United Mine Workers - 268 U.S. 295, 45 S. Ct. 551 (1925)

Rule:

The mere reduction in the supply of an article to be shipped in interstate commerce by the illegal or tortious prevention of its manufacture or production is ordinarily an indirect and remote obstruction to that commerce. But when the intent of those unlawfully preventing the manufacture or production is shown to be to restrain or control the supply entering and moving in interstate commerce, or the price of it in interstate markets, their action is a direct violation of the Anti-Trust Act.

Facts:

Plaintiff coal company employed union mine workers to operate its mine. The manager of the mine notified the president of the district union that he intended to run the mine on a non-union basis. The local union members organized a public protest and assaulted the coal company's guards. The coal company resumed mining under the protection of United States deputy marshals. When the coal was about to be shipped, a large force of local and district miners and their sympathizers, armed with rifles and other guns furnished and paid for by the district union, attacked the coal company's non-union employees and destroyed the property and equipment of four of the coal company's mines with dynamite and the torches. Subsequently, plaintiff instituted an action for treble damages under the Federal Anti-Trust Act against defendants. The district court entered a directed verdict in favor of defendants. The Circuit Court of Appeals for the Eighth Circuit affirmed. Plaintiff appealed. 

Issue:

Under the circumstances, could the defendant local mine workers unions and individual defendants be held liable under the Federal Anti-Trust Act?

Answer:

Yes.

Conclusion:

The court held that the direction of a verdict for the defendant local mine workers unions and individual defendants was erroneous because there was substantial evidence tending to prove that the purpose of the destruction on the part of the defendants was to stop the production of non-union coal and prevent its shipment to markets in other States where it would by competition tend to reduce the price of the commodity, and thus, affect injuriously the maintenance of wages for union labor in competing mines. However, with respect to the international mine workers union, the court affirmed the direction of the verdict, holding that although a corporation was responsible for the wrongs committed by its agents in the course of its business, it did not appear that the district union was doing the work of the international union in attacking the mines.