Mine Workers v. Bagwell, 512 U.S. 821 (1994)

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certiorari to the supreme court of virginia

No. 92-1625. Argued November 29, 1993—Decided June 30, 1994

A month after enjoining petitioners (collectively, the union) from conducting unlawful strike-related activities against certain mining companies, a Virginia trial court held a contempt hearing, fined the union for its disobedience, and announced that the union would be fined for any future breach of the injunction. In subsequent contempt hearings, the court levied against the union over $64 million in what it termed coercive, civil fines, ordering most of the money to be paid to the Commonwealth and the counties affected by the unlawful activities. After the strike was settled, the court refused to vacate the fines owed to the Commonwealth and counties, concluding that they were payable in effect to the public. Ultimately, it appointed respondent Bagwell to act as Special Commissioner to collect the unpaid fines. The Virginia Court of Appeals reversed and ordered that the fines be vacated. The Virginia Supreme Court, reversing in its turn, rejected petitioners' contention that the fines were criminal and could not be imposed absent a criminal trial.

Held: The serious contempt fines imposed here were criminal and constitutionally could be imposed only through a jury trial. Pp. 826-839. (a) A criminal contempt fine is punitive and can be imposed only through criminal proceedings, including the right to jury trial. A contempt fine is considered civil and remedial if it either coerces a defendant into compliance with a court order or compensates the complainant for losses sustained. United States v. Mine Workers, 330 U. S. 258, 303- 304. Where a fine is not compensatory, it is civil only if the contemnor has an opportunity to purge, such as with per diem fines and fixed, suspended fines. Pp. 826-830. (b) Most contempt sanctions share punitive and coercive characteristics, and the fundamental question underlying the distinction between civil and criminal contempts is what process is due for the imposition of any particular contempt sanction. Direct contempts can be penalized summarily in light of the court's substantial interest in maintaining order and because the need for extensive factfinding and the likelihood of an erroneous deprivation are reduced. Greater procedural protections are afforded for sanctions of indirect contempts. Certain indirect


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