# United Mine Workers v. Bagwell **Status: stub — expand.** **512 U.S. 821 (1994).** The Supreme Court held that a series of large, non-contingent fines imposed on a union for violating a labor injunction were **criminal** rather than civil contempt sanctions, and could not be imposed without the protections of a criminal prosecution — including, for serious penalties, a jury trial. The governing test the case supplies is one of **purpose and conditionality**, not of label or amount. A fine is civil if the contemnor can avoid it by complying — if it is "purgeable." A flat fine for a completed act, payable regardless of later compliance, is punishment, and punishment requires criminal process. It matters to enforcement of federal court orders because criminal contempt carries **no statutory maximum**, so the jury right cannot be determined from the charge in advance. It attaches by reference to the penalty actually imposed, measured against the petty-offence line. That is a separate and stacked question from the statutory jury-on-demand provision at 18 U.S.C. § 3691, which turns instead on whether the act was also a crime and on **who brought the underlying suit**. ## See also - [[How a Federal Court Order Is Enforced]] · [[Contempt of Court]] · [[Federal Rules of Criminal Procedure]]