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Peabody Holding Co., LLC v. UMW

United States Court of Appeals, Fourth Circuit

March 8, 2016

PEABODY HOLDING COMPANY, LLC, Delaware Limited Liability Company; BLACK BEAUTY COAL COMPANY, LLC, now known as Peabody Midwest Mining, LLC, Indiana Limited Liability Company, Plaintiffs - Appellants,
v.
UNITED MINE WORKERS OF AMERICA, INTERNATIONAL UNION, Unincorporated Association, Defendant - Appellee

Argued January 27, 2016

Page 155

Appeal from the United States District Court for the Eastern District of Virginia, at Alexandria. (1:13-cv-00458-LMB-IDD). Leonie M. Brinkema, District Judge.

ARGUED:

John R. Woodrum, OGLETREE, DEAKINS, NASH, SMOAK STEWART, P.C., Washington, D.C., for Appellants.

Arthur Traynor, III, UNITED MINE WORKERS OF AMERICA, Triangle, Virginia, for Appellee.

ON BRIEF:

W. Gregory Mott, Zachary S. Stinson, OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., Washington, D.C., for Appellants.

Diana Migliaccio Bardes, John Robert Mooney, MOONEY, GREEN, SAINDON, MURPHY & WELCH, P.C., Washington, D.C., for Appellee.

Before WILKINSON, SHEDD, and AGEE, Circuit Judges.

OPINION

Page 156

WILKINSON, Circuit Judge.

In this case we must decide when and under what circumstances courts should review a labor arbitrator's decision. For the reasons given below, we hold that judicial involvement in the labor dispute in this case was premature. Under the complete arbitration rule, the arbitrator should have been given the opportunity to resolve both the liability and remedial phases of the dispute between the Companies and the Union before it moved to federal court. We therefore vacate the district court's order confirming the merits of the arbitrator's liability decision and direct that court to return the dispute to the arbitrator to allow him to rule on the remedial issues and otherwise complete the arbitration task.

I.

The dispute in this case arises out of a 2007 Memorandum of Understanding Regarding Job Opportunities (the " Jobs MOU" ) signed by the United Mine Workers of America (the " Union" ) and Peabody Coal Company (" Peabody Coal" ) as part of a wider collective bargaining agreement. Peabody Coal signed the Jobs MOU on behalf of itself and as a limited agent of its corporate parent, Peabody Holding Company

Page 157

(" Peabody Holding" ), and several of Peabody Holding's other subsidiaries, including Black Beauty Coal Company (" Black Beauty" ). The principal purpose of the Jobs MOU was to require non-unionized companies within the Peabody corporate family to give preferential hiring treatment to coal miners who were either working for or laid off by Peabody Coal. An arbitration clause in the Jobs MOU provided that a " Jobs Monitor" was to resolve any disputes involving the Jobs MOU, and that his decisions would be " final and ...


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