## Facts

- Coal-mining companies in Sebastian County, Arkansas operated mines that shifted from union to nonunion labor in 1914.
- District No. 21 of the United Mine Workers of America (UMWA), related local unions, and individual members opposed nonunion operations.
- After the mines reopened with nonunion workers, union miners and supporters attacked guards and workers; an injunction followed but conflict continued.
- On July 17, 1914, a large group associated with District 21, armed with weapons allegedly provided through District 21, assaulted the mines, destroyed structures and equipment, and drove off nonunion employees, effectively shutting down production.
- The companies sued under the Sherman Act, alleging a conspiracy to stop production and shipment of nonunion coal to out-of-state markets to affect interstate supply and prices.
- After an earlier Supreme Court reversal for insufficient proof of a commerce-directed purpose, the second trial included new evidence (e.g., District 21 minutes and officer testimony) indicating an intent to keep nonunion coal from competing in interstate markets.
- The district court directed a verdict for defendants; the Eighth Circuit affirmed.

## Issues

1. Whether the evidence permitted a jury to find that the destruction of the mines was intended to restrain interstate commerce in coal by preventing nonunion coal from entering out-of-state markets and affecting prices, creating a Sherman Act violation.
2. Whether the international UMWA could be held liable for District 21’s conduct absent proof that the international authorized, financed, or ratified the strike and violence.

## Decision

- The Supreme Court affirmed in part and reversed in part, and remanded.
- As to District 21, local unions, and related defendants, the Court held there was substantial evidence from which a jury could find an intent to restrain interstate commerce by stopping production of nonunion coal to prevent its interstate shipment and competitive price effects; directing a verdict for these defendants was error.
- As to the international UMWA, the Court held the evidence did not establish organizational participation or agency-based responsibility where the union constitution allowed district-called local strikes without international sanction and the strike lacked formal authorization or financing by the international.

## Legal Principles

- Tortious interference with production that merely reduces goods later shipped interstate is ordinarily an indirect and remote effect on interstate commerce and does not, by itself, establish a Sherman Act violation.
- When unlawful acts preventing production are done with the intent to restrain or control the supply entering interstate commerce, or to affect prices in interstate markets, the conduct may constitute a direct restraint actionable under the Sherman Act.
- Evidence of a mine’s potential significance in interstate markets, combined with proof of purpose to prevent interstate shipment and competition, can support a jury finding of a commerce-directed antitrust conspiracy.
- An international union is not automatically liable for a district’s strike-related torts where the district acts on its own responsibility under the union constitution and there is no proof of international authorization, ratification, or agency-sufficient organizational participation.

## Conclusion

The Court held that violence destroying nonunion mines could fall within the Sherman Act when supported by evidence of a purpose to restrict interstate coal supply or affect interstate prices, requiring jury consideration as to the district and local union defendants, but it rejected liability for the international union absent proof of authorization or organizational participation.


Coronado Coal Co. v. United Mine Workers of Am., 268 U.S. 295 (1925)