Coronado Coal Co. v. United Mine Workers (Coronado II)

Nine coal-mining corporations (mining corporations) (plaintiffs) operated collectively in Sebastian County, Arkansas, using union labor from the United Mine Workers of America (international union), District No. 21 (District 21) (defendants). The union’s contract with the mining corporations was set to expire on July 1, 1914. In March, the manager of the mines notified the union’s president that the mines would no longer use union labor. On April 6, 1914, the day the mines were set to reopen using nonunion labor, District 21 laborers injured several hired guards at the mines. After an injunction was issued against the District 21 miners, work at the mines continued using nonunion labor. On July 17, 1914, union members and their supporters, armed with weapons provided by District 21, attacked nonunion laborers at the mines and destroyed the mining corporations’ property and equipment. The mining corporations sued the international union and District 21 under §§ 1 and 2 of the Sherman Act. In Coronado I, on review from a ruling by the United States Court of Appeals for the Eighth Circuit granting damages to the mining corporations, the Supreme Court held there was insufficient evidence to show that District 21 had intentionally restrained interstate commerce in violation of the act. The Court therefore reversed the Eighth Circuit’s ruling and remanded the case to the district court. At a new district-court trial, the mining corporations presented new evidence regarding the July 17 attack, including notes from a District 21 convention and testimony from a former District 21 officer, showing that District 21 leadership often discussed tactics to keep union coal competitive with nonunion coal from other states. The district court issued a directed verdict and judgment in favor of District 21, which the Eighth Circuit affirmed. The mining corporations appealed.