UNITED MINE WORKERS v. CORONADO COAL COMPANY 259 U.S. 344 (1922) CORONADO COAL COMPANY v. UNITED MINE WORKERS 268 U.S. 295 (1925)

In two nearly identical cases, the Supreme Court provided opposite answers to the same question: does the sherman antitrust act apply to local strikes that indirectly restrain commerce? The United Mine Workers (UMW) struck to prevent an employer from closing its mines despite valid union contracts; violence and property damage resulted. The company sued the union claiming a Sherman Act conspiracy to restrain interstate commerce. In its defense, the UMW claimed that it was exempt from suit because it was unincorporated and, because mining was local, that there had been no Sherman Act violation. On appeal to the Supreme Court, Chief Justice william howard taft declared for a unanimous bench that, although unions (even though unincorporated) could clearly be sued, the union had not violated the Sherman Act here. Mining was merely local; any interference concerned the production rather than the distribution of goods. Taft said no restraint of trade existed, absent an explicit showing of intent to restrain trade, unless the obstruction had "such a direct, material and substantial effect to restrain [commerce] that intent reasonably may be inferred." Taft thus introduced new tests of reasonableness (see rule of reason) and intent.

The company soon appealed with new evidence. Again unanimous, the Supreme Court now said that when intent to restrain trade attended a decrease in production, a previously "indirect and remote obstruction" became a direct interference in violation of the law. The Court asserted that the evidence at the second trial demonstrated such intent. The Court's near reversal, a finding of intent where none had previously existed, probably resulted from a fear of the implications of the first decision. The effect of the later opinion was to hamper union organizing efforts and cast doubt on the legality of strikes generally; certainly intent could be found by Justices who were looking for it.

David Gordon
(1986)

(see also: Labor and the Antitrust Laws.)