New York City Transit Authority v. Transport Workers Union of America

Local 100 of the Transport Workers Union of America, AFL-CIO (Local 100) (defendant) represented hourly workers of the New York City Transit Authority and the Manhattan and Bronx Surface Transit Operating Authority (transit authorities) (plaintiffs). The parties’ collective-bargaining agreement (CBA) expired in mid-December 2005. Local 100 members planned to strike if a new CBA was not in place by December 16. On December 12, the transit authorities sued under New York’s Taylor Law to enjoin Local 100 from striking. The court enjoined the strike, but Local 100 went on strike anyway on December 20, effectively shutting down the city’s transit systems. The transit authorities moved to hold Local 100 in criminal contempt, seeking a $1 million fine for violating the injunction that would double each day the strike continued. Local 100 argued that it had a Sixth Amendment right to a jury trial on the contempt issue and that the proposed fines were excessive, among other things. The transit authorities countered by explaining the disruption and cost caused by transit strikes. The transit authorities also showed that Local 100 had millions of dollars in assets. The court denied Local 100’s request for a jury trial, found Local 100 in contempt, and fined it $1 million for each day it remained on strike, for a total of $2.5 million. Local 100 appealed.