Coronado Coal Co. v. United Mine Workers of America

Coronado Coal Co. v. United Mine Workers of America refers here to two separate cases heard by the U.S. Supreme Court during the tenure of Chief Justice William Howard Taft. Both arose from Arkansas’s Sebastian County Union War of 1914 and featured the same parties: the Coronado Coal Company and District No. 21, a local Arkansas branch of the United Mine Workers of America (UMWA).

The first case, United Mine Workers of America v. Coronado Coal Co. (1922), was an appeal that ruled in favor of the union. It overturned a lower court decision by the Court of Appeals that found the union in violation of the Sherman Antitrust Act during the strike. The Supreme Court, however, found little evidence that the union conspired to restrict the movement of non-union coal to markets outside of Arkansas. It also established a federal precedent that unincorporated unions could be party to civil suits.

In the second case, Coronado Coal Co. v. United Mine Workers of America (1925), the company re-filed its petition, citing new evidence. This Coronado case found that the local union had indeed violated antitrust law and conspired to hinder interstate trade. The Court unanimously reversed its earlier decision. This was a setback for organized labor. The ruling blurred the legal standing of strikes that interfered with goods entering interstate commerce.

Background
In 1914, Franklin Bache, who operated coal-mining companies in western Arkansas, attempted to work around union-shop agreements by leasing one of his companies to another “shell” organization that had not been party to any prior contract. This non-union mine in Sebastian County was in the center of the state’s coal industry, an area where the UMWA had been active since the end of the nineteenth century. In the summer, Bache, along with Heber Denman, opened their non-union mine under the guard of deputies and professional strikebreakers. Physical and legal battles soon followed, initiating the Sebastian County Union War of 1914.

During the labor conflict,Bache and Denman, via Coronado Coal Co., brought suit against the UMWA in the District Court for the Western District of Arkansas. They alleged that the local union, District No. 21, had destroyed property in order to restrict and impede interstate trade. Under Section 7 of the Sherman Antitrust Act, the court was to treble the affirmed damages if the union was deemed liable. After a series of litigations, the Court of Appeals affirmed the earlier district court’s ruling in favor of the company.

First Coronado Case
The UMWA appealed the case before the U.S. Supreme Court in 1922. In the firstCoronadocase, the Court overturned the Court of Appeals ruling, finding that the unionhad not violated the Sherman Antitrust Act. It reasoned that federal antitrust law did not extend to the local union since there was little evidence to suggest it had conspired to interfere with the movement of goods in interstate commerce. It also established a federal precedent that the unincorporated union was subject to a suit by the company. The latter ruling was controversial to some national labor leaders, such as Samuel Gompers, who thought it could weaken unions by increasing their liability.

Second Coronado Case
After the defeat, the Coronado Coal Co. sought a new approach. Since the opinion of the Supreme Court had noted that the company had not provided evidence of the union’s intent to hinder interstate commerce under the Sherman Antitrust Act, the company began a search for such evidence. In particular, it needed to prove that the union had conspired to restrict or prevent trade, and suppress competition, for non-union coal.

The company entered an amended complaint that worked its way to the U.S. Supreme Court as Coronado Coal Co. v. United Mine Workers of America in 1925. The company used the testimony of a new witness, James K. McNamara, who had been a leader during the violence in the 1914 labor conflict and had served as a secretary for a local union. McNamara claimed that he had met with District No. 21 president Pete Stewart and UMWA president John P. White in 1914. He alleged to have been involved in a discussion about stopping Coronado “scab dug” coal from reaching the marketplace. This meant Stewart and White had deliberately plotted to impede interstate commerce. McNamara further noted that White had instructed him to tell the workers about the plan, and that Stewart had offered firearms to mine families so that they could help restrict the movement of non-union coal.

In light of this evidence, Taft delivered the Court opinion in favor of the company. It ruled that the evidence proved the union’s intent to restrict the movement of non-union coal to markets beyond Arkansas, and therefore that it hampered interstate commerce. The ruling fell against District No. 21, the local union, rather than the national UMWA.

On October 13, 1927, the company and union settled the case, with the union paying $27,500. The case left an impact on the labor movement itself, presenting new questions about the legality of strikes that affected goods moving into interstate trade. In Arkansas, the Coronado cases also served as a watershed; in the aftermath, coal mines became predominately non-union.

For additional information:
Coronado Coal Co. et al. v. United Mine Workers of America et al., 268 U.S. 295 45 (1925).

United Mine Workers v. Coronado Coal Co., 259 U.S. 344 (1922).

“The Coronado Coal Case” Yale Law Journal 32 (November 1922): 59–65.

Alvarez, H. G. Fire in the Hole: The Story of Coal Mining in Sebastian County, Arkansas. Greenwood, AR: South Sebastian County Historical Society, 1983.

Dubofsky, Melvyn. The State and Labor in Modern America. Chapel Hill: University of North Carolina Press, 1994.

Gregory, Charles O. Labor and the Law. New York: W. W. Norton & Co., 1961.

McDonough, J. B. United Mine Workers of America, Coronado Coal Company (n.d.). Transcript : United Mine Workers, et al., plaintiffs in error vs Coronado Coal Company, et al., 1915–1920.

Moore, Jerry H., and Lonnie C. Roach. No Smoke, No Soot, No Clinkers: A History of the Coal Industry in South Sebastian County. N.p.: Frank Boyd, 1974.

Northrup, Herbert R., and Gordon F. Bloom. Government and Labor. Homewood, IL: Richard D. Irwin, 1963).

O’ Brien, Ruth. Workers’ Paradox: The Republican Origins of New Deal Labor Policy, 1886–1935. Chapel Hill: University of North Carolina Press 1998.

Sizer, Samuel A. “‘This is Union Man’s Country’: Sebastian County, 1914.” Arkansas Historical Quarterly 27 (Winter 1968): 306–329.

Taylor, Benjamin J., and Fred Witney. Labor Relations Law. Englewood Cliffs, NJ: Prentice Hall, 1979.

Ryan Driskell Tate
St. Paul, Minnesota