United States v. United Mine Workers of America
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
A Rhode Island court also chose a stricter notice rule for its own criminal procedure; that choice does not change the federal rule. One flagged opinion, United States v. McKnight (1979), contains no citation to United Mine Workers in its full text and produced no entry.
44 later cases cite United States v. United Mine Workers of America; 44 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on United States v. United Mine Workers of America?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Seventh Circuit declined to extend United Mine Workers' rule about challenges to injunctions to a challenge against a local court rule.
In the Matter of Frank W. Oliver, Attorney · Seventh Circuit · filed
As its principal authority for this proposition, the Government cites Walker v. Birmingham, 388 U.S. 307, 87 S.Ct. 1824, 18 L.Ed.2d 1210 (1967), and United States v. United Mine Workers, 330 U.S. 258, 67 S.Ct. 677, 91 L.Ed. 884 (1947), and argues that both were cases involving injunctions which were violated where the validity of the injunctions and the statutes on which they were based was not permitted to be challenged in contempt of court proceedings which resulted from such violations. ... We do not believe the analogy the Government seeks to draw is an appropriate one. ... We hold that this case is not governed by the injunction eases and that Oliver may properly challenge the validity of the district court’s policy statement.
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The Illinois Appellate Court recognized a Fifth Amendment exception to United Mine Workers' rule that court orders must be obeyed.
People ex rel. Kunce v. Hogan · Illinois Appellate Court, Fifth District · filed
As the State contends, all orders and judgments of courts must be complied with promptly, even if believed incorrect. (United States v. United Mine Workers of America, 330 U.S. 258, 91 L. Ed. 884, 67 S. Ct. 677 (1947).) But that general rule does not apply where the order is to reveal information which is asserted to be self-incriminating. (Maness v. Meyers, 419 U.S. 449, 464, 42 L. Ed. 2d 574, 586-87, 95 S. Ct. 584, 594 (1975).)
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The Seventh Circuit held that United Mine Workers' reference to proof of actual loss did not foreclose an award of the contemnor's profits as compensation.
Connolly v. J.T. Ventures · Seventh Circuit · filed
J.T. Ventures’ reliance on ... United States v. United Mine Workers, ... is therefore misplaced.
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The district court confined United Mine Workers' jurisdictional injunction ruling to the emergency and preservation of existing conditions before it.
Shifrin v. Group Health Plan, Inc. · E.D. Missouri · filed
She cites the case of United States v. United Mine Workers of America, 330 U.S. 258, 67 S.Ct. 677, 91 L.Ed. 884 (1947) in support of her position. The Court has carefully reviewed this case and finds that it is limited to its facts and not applicable in the present situation.
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The district court held that United Mine Workers did not bar disgorgement of profits as compensation for civil contempt.
ePlus Inc. v. Lawson Software, Inc. · E.D. Virginia · filed
United Mine Workers did not overrule Leman. The focus of the decision in United Mine Workers was primarily the validity of injunction orders, not civil contempt remedies. And, to the extent that, in United Mine Workers, the Supreme Court analyzed civil contempt remedies, it did so only in the context of the proper scope and wording of coercive civil contempt remedies. No compensatory remedy was at issue in United Mine Workers. Nor was disgorgement of profits at issue.
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