830
Opinion of the Court
and n. 11 (suspended or probationary sentence is criminal). Mine Workers involved a $3,500,000 fine imposed against the union for nationwide post-World War II strike activities. Finding that the determinate fine was both criminal and excessive, the Court reduced the sanction to a flat criminal fine of $700,000. The Court then imposed and suspended the remaining $2,800,000 as a coercive civil fine, conditioned on the union's ability to purge the fine through full, timely compliance with the trial court's order.4 The Court concluded, in light of this purge clause, that the civil fine operated as "a coercive imposition upon the defendant union to compel obedience with the court's outstanding order." 330 U. S., at 307.
This Court has not revisited the issue of coercive civil contempt fines addressed in Mine Workers. Since that decision, the Court has erected substantial procedural protections in other areas of contempt law, such as criminal contempts, e. g., Bloom v. Illinois, 391 U. S. 194 (1968), and summary contempts, e. g., Taylor v. Hayes, 418 U. S. 488 (1974); Codispoti v. Pennsylvania, 418 U. S. 506, 513 (1974); Johnson v. Mississippi, 403 U. S. 212 (1971); In re Oliver, 333 U. S. 257, 275 (1948). Lower federal courts and state courts such as the trial court here nevertheless have relied on Mine Workers to authorize a relatively unlimited judicial power to impose noncompensatory civil contempt fines.
B
Underlying the somewhat elusive distinction between civil and criminal contempt fines, and the ultimate question posed
4 Although the size of the fine was substantial, the conduct required of the union to purge the suspended fine was relatively discrete. According to the Court, purgation consisted of (1) withdrawal of the union's notice terminating the Krug-Lewis labor agreement; (2) notifying the union members of this withdrawal; and (3) withdrawing and notifying the union members of the withdrawal of any other notice questioning the ongoing effectiveness of the Krug-Lewis agreement. United States v. Mine Workers, 330 U. S. 258, 305 (1947).
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