Mine Workers v. Coronado Coal Company

Supreme Court of the United States · 1922 · Corporations

259 U.S. 344 (1922)

Updated August 22, 2026

CorporationsUnincorporated associationsAntitrustLabor unionsInterstate commerceFederal procedurelabor union suabilityunincorporated association

Facts

The Prairie Creek, Mammoth Vein, and Coronado mines had been operated with union labor, but Bache decided in 1914 to run them on a non-union basis and prepared to reopen with guards, rifles, and replacement workers. District No. 21 and local union officers declared a local strike, and on April 6 union miners and sympathizers attacked the mine, assaulted guards, stopped operations, and caused the mine to fill with water. During the following months District officers and union men continued efforts to prevent non-union operations, including buying rifles and threatening to stop the mine from running non-union. On July 17 a large armed force attacked from several sides, burned and dynamited the mining plant, and killed two of Bache's employees after capture.

Issue

Whether the unincorporated labor unions were suable in federal court in their association names and whether the evidence supported liability of the International Union or District No. 21 under the Anti-Trust Act. More specifically, the Court considered whether this local strike and destruction of mining property was shown to be part of a conspiracy to restrain or monopolize interstate commerce.

Rule

An unincorporated labor union that functions as a unified body with officers, funds, and organized action may be sued in federal court as an association, and funds accumulated for strike purposes may be subjected to execution for torts committed by the union in carrying out its united purpose. But for Sherman Act liability based on obstruction of production, it must appear by direct evidence, obvious consequence, or circumstances that the conspiracy intended to injure, obstruct, restrain, or monopolize interstate commerce, or that the conduct necessarily had such a direct, material, and substantial effect on interstate commerce that intent may reasonably be inferred; coal mining itself is not interstate commerce, and obstruction of mining alone is not enough.

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The Riverbend Mill Workers is an unincorporated union with 18,000 members across Missouri and Kansas. It has elected officers, a constitution, a treasury funded by dues, and a strike fund used through centralized accounting to support walkouts. After union members allegedly destroy a warehouse during a strike in St. Louis, the warehouse owner sues the union in federal court under the union's association name.

What is the strongest argument that the suit against the union may proceed in its association name?

Explanation. The majority treated suability as a procedural matter driven by practical necessity. Where an unincorporated labor union has organized leadership, accumulated funds, and capacity for unified action, it may be sued in federal court as an association. The Court rejected the idea that injured parties must sue every member individually.