In the case of Carbon Fuel Co. v. United Mine Workers of America, 1979, the U.S Supreme Court ruled that a union could not be held responsible for illegal strikes by its members unless it was proven that the union had instigated, supported or ratified those strikes. The court's decision came after Carbon Fuel Company sued United Mine Workers of America (UMWA) and several local unions for damages resulting from wildcat strikes at their mines in West Virginia which violated a no-strike clause in their collective bargaining agreement. The company argued that UMWA should be liable as they failed to take steps to prevent these unauthorized work stoppages or penalize those involved. However, the court concluded there was insufficient evidence showing UMWA endorsed these actions and stated under federal labor law (the Taft-Hartley Act), mere negligence on part of a union is not enough to establish liability; rather active involvement must be demonstrated.

In the dissenting opinion for Carbon Fuel Co. v. United Mine Workers of America, it was argued that the majority's decision to hold unions liable for individual members' actions during strikes went against established labor law principles and precedent. The dissent emphasized that a union should only be held responsible if there is clear evidence of its involvement or authorization in illegal activities by its members, which wasn't proven in this case. They also pointed out that holding unions accountable without such proof could potentially undermine their ability to effectively represent their members and engage in collective bargaining processes, thereby weakening workers' rights overall.