## Facts

- During World War II, the United States seized and operated the nation’s bituminous coal mines under federal authority.
- A labor dispute arose between the government-operated mines and the United Mine Workers of America (UMWA) over contract terms.
- UMWA president John L. Lewis gave notice terminating the existing agreement and called a nationwide strike.
- The United States filed suit in federal district court seeking declaratory relief and injunctive relief to prevent the union and Lewis from calling or supporting a strike and from interfering with mine operations.
- The district court issued a temporary restraining order (TRO); the miners struck in defiance of the TRO.
- The district court issued an order to show cause, rejected the argument that the Norris–La Guardia Act (and Clayton Act § 20) removed jurisdiction to issue labor injunctions, extended the TRO, later issued a preliminary injunction, and found Lewis and UMWA guilty of criminal contempt.
- The district court imposed criminal contempt fines of $10,000 on Lewis and $3.5 million on UMWA.
- The court of appeals stayed enforcement pending appeal; the Supreme Court granted review before final judgment.

## Issues

1. Whether the Norris–La Guardia Act and Clayton Act § 20 deprived the district court of jurisdiction to issue a TRO and preliminary injunction in a labor dispute involving government-operated mines.
2. Whether, even if applicability of the labor anti-injunction statutes was uncertain, the district court could issue a TRO to preserve the status quo while determining jurisdiction and punish disobedience as criminal contempt.
3. Whether the criminal contempt fines against Lewis and UMWA were authorized and properly imposed.

## Decision

- The Supreme Court held that the Norris–La Guardia Act and Clayton Act § 20 did not bar the district court from issuing a TRO and preliminary injunction in a suit by the United States to prevent a nationwide strike affecting mines being operated by the government.
- The Court further held that, even assuming the labor anti-injunction statutes applied, the district court had power to issue a restraining order to preserve existing conditions while deciding its own jurisdiction, and violation of that order could be punished as criminal contempt.
- The Court affirmed the district court’s authority to impose criminal contempt sanctions for deliberate disobedience of its orders.
- The Court upheld the imposition of contempt fines in principle but modified aspects of the monetary sanctions in light of the posture of the case and subsequent events.

## Legal Principles

- The restrictive labor-injunction provisions of the Norris–La Guardia Act and Clayton Act § 20 do not categorically bar injunctive relief when the United States sues in its sovereign capacity to protect continuity of government-operated operations.
- For these statutes, the general term “employer” does not include the federal government; disputes between the government and those working in government-run operations are not treated as ordinary private labor disputes for anti-injunction purposes.
- A federal court with a colorable basis for jurisdiction may issue interim orders to preserve the status quo while determining jurisdiction, and parties must comply unless and until the order is stayed, modified, or reversed through proper process.
- Disobedience of a TRO or injunction may be punished as criminal contempt unless the issuing court was transparently without jurisdiction.
- Criminal contempt fines may be imposed on both individual union officers and the union entity to punish past defiance of court orders, distinct from civil contempt sanctions aimed at coercing future compliance.

## Conclusion

The Court concluded that federal labor anti-injunction statutes did not strip jurisdiction for the United States to obtain injunctive relief to prevent a nationwide strike in government-operated mines, and it reaffirmed that court orders must be obeyed pending review, with willful violations punishable as criminal contempt.


United States v. United Mine Workers of Am., 330 U.S. 258 (1947)