HELVETIA COAL COMPANY v. UNITED MINE WORKERS OF AMERICA, INTERNATIONAL UNION
1:20-cv-01476
D.D.C.Jun 26, 2018Background
- CONSOL subsidiaries (Helvetia, Laurel Run, Island Creek, Amonate) are signatories to the 2011 NBCWA, which expired Dec. 31, 2016; CONSOL (parent) negotiated post-expiration changes to retiree benefits (Plan).
- Union filed ROD No. 11-0143 (grievance to Trustees) seeking determination that employers may not unilaterally change retiree benefits post-expiration; Trustees ruled for the Union on Oct. 31, 2017.
- Union plaintiffs sued CONSOL in the Southern District of West Virginia (first-filed) seeking injunctive relief; West Virginia court issued a preliminary injunction and treated CONSOL as real party in interest/agent of subsidiaries.
- CONSOL’s subsidiaries filed actions in the W.D. Pa. seeking to vacate the Trustees’ award and declaratory relief about post-termination arbitration/obligations; an earlier Pennsylvania action by the subsidiaries was previously transferred to West Virginia.
- After the Trustees’ award and procedural developments in the West Virginia case (Union plaintiffs amended to add subsidiaries), the Union moved to dismiss or transfer the instant Pennsylvania suit under the first-filed rule.
- The Western District of Pennsylvania applied the first-filed rule and transferred the case to the Southern District of West Virginia for consolidation/consideration.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the first-filed rule bars Pennsylvania suit | Pennsylvania plaintiffs argued parties and issues do not substantially overlap and equity disfavors transfer | Union argued West Virginia action was first-filed and substantially overlaps in parties, facts, and issues | Court applied first-filed rule and transferred case to S.D. W.Va. |
| Whether the parties are identical/real parties in interest | Plaintiffs said subsidiaries (not CONSOL) are the real parties and differ from West Virginia defendants | Union and West Virginia court found CONSOL is agent/real party in interest of subsidiaries, collapsing difference | Court found party difference illusory and substantial overlap of parties |
| Whether issues are substantially similar (arbitral award/confirmation/vacatur) | Plaintiffs contended some issues are distinct and asked this court to adjudicate arbitral-vacatur question first-filed in PA | Union noted West Virginia action seeks to confirm/enforce the same Trustees’ award and obtained injunctive relief related to arbitration | Court found significant overlap (both challenge/seek enforcement of Trustees’ decision) and deferred to first-filed court |
| Whether any exception to the first-filed rule applies | Plaintiffs invoked equity and contended lack of identical overlap to avoid transfer | Union asserted no exceptional circumstances exist to defeat the rule | Court held plaintiffs did not meet burden to show exception; transfer ordered |
Key Cases Cited
- Crosley Corp. v. Hazeltine Corp., 122 F.2d 925 (3d Cir. 1941) (adopting the first-filed rule principle that the court first having possession should decide the controversy)
- Chavez v. Dole Food Co., Inc., 836 F.3d 205 (3d Cir. 2016) (first-filed rule promotes flexible responses—stay, transfer, or dismissal—when concurrent jurisdiction exists)
- EEOC v. Univ. of Pennsylvania, 850 F.2d 969 (3d Cir. 1988) (first-filed rule advances sound judicial administration and comity among equal federal courts)
- Pittsburgh Logistics Sys., Inc. v. C.R. England, Inc., 669 F. Supp. 2d 613 (W.D. Pa. 2009) (first-filed rule applies where actions are identical or substantially overlap)