## Facts

- Coal companies obtained a Virginia injunction restricting unlawful strike-related conduct, including violence, blocking access, and exceeding picket limits.
- After finding 72 violations, the trial court imposed $642,000 in fines and announced preset penalties for future violations ($100,000 for violent violations; $20,000 for nonviolent violations).
- In later hearings, the court found more than 400 additional out-of-court violations and imposed over $64 million in fines labeled “coercive, civil fines.”
- Approximately $12 million was ordered payable to the companies and roughly $52 million to the Commonwealth of Virginia and two counties.
- Proceedings were conducted by the judge without a jury; the court required proof beyond a reasonable doubt but did not provide criminal-trial protections.
- After the strike ended, the trial court refused to vacate most fines and appointed a special commissioner to collect them.
- Virginia’s appellate court ordered the fines vacated, but the state supreme court reinstated them as civil contempt because the union had been warned and could have complied with the injunction.
- The U.S. Supreme Court granted review.

## Issues

1. Whether the large, preset fines imposed for numerous out-of-court violations of an injunction were civil contempt sanctions or criminal contempt sanctions.
2. Whether imposing those fines without a jury trial violated constitutional requirements applicable to criminal contempt.

## Decision

- The U.S. Supreme Court reversed the judgment upholding the fines.
- The Court held the “serious contempt fines” were criminal contempt sanctions.
- Because the fines were criminal, they could be imposed only through criminal proceedings, including a jury trial.

## Legal Principles

- A contempt sanction is civil only if it is remedial: it either (a) coerces compliance with a court order, typically through a purge mechanism, or (b) compensates the complainant for actual losses.
- Noncompensatory fines are civil only if the contemnor has a meaningful opportunity to purge the sanction through compliance (e.g., per diem fines that stop upon compliance, or fixed fines suspended on condition of future obedience).
- Fixed, retrospective fines for completed violations that cannot be avoided or reduced through later compliance are punitive and therefore criminal contempt.
- The civil/criminal classification turns on the substance and effect of the sanction and the process due, not the court’s label or the fact that the contemnor was warned beforehand.
- Indirect contempt involving widespread, out-of-court violations of a complex injunction typically requires greater procedural safeguards; when sanctions are criminal, due process includes the right to a jury trial.

## Conclusion

The Court concluded that massive, preset fines imposed after the fact for extensive out-of-court violations of a complex injunction, and not tied to compensation or purgeable through compliance, are criminal contempt sanctions that require criminal procedural protections, including a jury trial.


Int’l Union, United Mine Workers of Am. v. Bagwell, 512 U.S. 821 (1994)