Peabody Holding Co. v. United Mine Workers of America
2012 U.S. App. LEXIS 556
| 4th Cir. | 2012Background
- Jobs Agreement (1993) binds Peabody Coal, its parent Peabody Holding, and Black Beauty; includes Jobs Monitor with arbitration.
- Agreement aims to provide job opportunities to laid-off/active miners and applies to nonsignatory operations, with termination date of Dec 31, 2011.
- Peabody Holding divested from Peabody Coal in 2007; Peabody Holding argues it no longer bound by the Jobs Agreement.
- Union grievance alleges noncompliance by Peabody Holding and Black Beauty; Jobs Monitor initially found arbitrability but deferred merits.
- District court ruled for the Union, holding the Jobs Monitor or court could decide arbitrability; Fourth Circuit affirms that court must decide arbitrability and that dispute is arbitrable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Who decides arbitrability the court or the arbitrator | Peabody Holding: arbitrability decided by arbitrator | Union: arbitrability governed by broad clause; arbitrator could decide | Court must decide arbitrability |
| Whether the dispute is arbitrable under the Jobs Agreement | Dispute not arbitrable due to severed corporate ties | Presumption of arbitrability; dispute falls within contract scope | Dispute arbitrable; must proceed to arbitration |
| Durational issues can be resolved by arbitrator under the Jobs Agreement | Durational dissolution invalidates arbitration | Arbitrator may interpret contract to resolve durational questions | Durational interpretation is arbitrable; arbitrator may resolve under the Jobs Agreement |
Key Cases Cited
- Carson v. Giant Food, Inc., 175 F.3d 325 (4th Cir.1999) (clear intent required to arbitrate arbitrability; not here)
- AT&T Technologies, Inc. v. Communications Workers of America, 475 U.S. 643 (1986) (arbitrability questions for courts absent clear language)
- First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (U.S. 1995) (presumption in favor of arbitration; two-step inquiry)
- Rent-A-Center, West, Inc. v. Jackson, 130 S. Ct. 2772 (2010) (reaffirmed 'clear and unmistakable' standard for arbitratability)
- Warrior & Gulf Navigation Co., 363 U.S. 574 (1960) (arbitrability policy language guiding court’s role)
- Virginia Carolina Tools, Inc. v. Int'l Tool Supply, Inc., 984 F.2d 113 (4th Cir.1993) (durational issues treated specially; less force in presumption in certain cases)
- Granite Rock Co. v. Teamsters, 130 S. Ct. 2847 (2010) (limits on using 'clear and unconscionability' in contract formation to deny arbitration)