Peabody Holding Co. v. United Mine Workers International Union, 41 F. Supp. 3d 494

PHC and Black Beauty (subsidiaries of Peabody Energy) were bound by a 2007 Memorandum of Understanding (MOU) incorporated into the National Bituminous Coal Wage Agreement, requiring non‑union affiliates to offer 3 of 5 new classified jobs to PCC employees; the MOU expired Dec. 31, 2011 and included a Jobs Monitor arbitration clause.
In Oct. 2007 Peabody spun off PCC (to Patriot) but retained PHC and Black Beauty; the Union asserted the MOU obligations survived the spinoff and filed a grievance with the Jobs Monitor.
The Jobs Monitor ruled the dispute arbitrable and, after bifurcated proceedings, issued an award holding PHC/Black Beauty remained bound by the MOU post‑spinoff and reserved certain exemption/remedy questions for a later stage.
PHC and Black Beauty sued in federal court seeking vacatur of the Award; the Union moved to enforce the Award and compel completion of remedies arbitration.
The district court held the liability portion of the Award was a final, reviewable award, rejected plaintiffs’ contract‑interpretation and NLRA preemption (Sections 8(b) and 8(e)) challenges, and granted summary judgment enforcing the Award and remanding remedial issues to the Jobs Monitor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the liability award is reviewable/final	Award is interlocutory because remedies remain; court lacks jurisdiction	Liability ruling is a final partial award and reviewable	Award as to liability is final and reviewable
Whether Award exceeds arbitrator's authority / fails to draw essence from contract	Jobs Monitor misapplied contract; new 2011 agreements superseded the 2007 MOU	Arbitrator interpreted and applied the contract within his authority	Award draws its essence from the agreement; court defers to arbitrator
Whether enforcement violates NLRA § 8(b)(1)(A) and 8(b)(2) (hiring preference based on union membership)	Post‑spinoff preference would be based on union membership, unlawful	MOU forbids discrimination on union membership; preference is seniority/experience tied to PCC work	§§ 8(b)(1)(A) and 8(b)(2) not violated; preference is for PCC work experience, not mere union status
Whether enforcement violates NLRA § 8(e) (secondary/anti‑neutral restraints)	Post‑spinoff MOU would impermissibly constrain neutral employers and coerce business relations	MOU is a lawful work‑preservation (primary) agreement; plaintiffs are not neutral because parent’s spinoff was voluntary conduct relinquishing control	§ 8(e) does not bar enforcement; MOU is a valid work‑preservation agreement and plaintiffs are offending employers

Arbaugh v. Y & H Corp., 546 U.S. 500 (statutory jurisdiction allocation and burden on plaintiff)
General Drivers, Warehousemen & Helpers Local Union No. 89 v. Riss & Co., 372 U.S. 517 (LMRA §301 authorizes courts to enforce final arbitration awards)
Misco, Inc. v. United Paperworkers Int’l Union, 484 U.S. 29 (deferential review: arbitrator must at least arguably construe/apply contract)
United Steelworkers of America v. Enterprise Wheel & Car Corp., 363 U.S. 593 (arbitrator constrained to interpretation/application of collective bargaining agreement)
Mountaineer Gas Co. v. Oil, Chem. & Atomic Workers Int’l Union, 76 F.3d 606 (Fourth Circuit description of arbitral‑review standard)
Providence Journal Co. v. Providence Newspaper Guild, 271 F.3d 16 (partial liability awards in bifurcated arbitration can be final and reviewable)
Kaiser Steel Corp. v. Mullins, 455 U.S. 72 (courts must determine legality of labor contract before enforcing)
National Labor Relations Bd. v. Int’l Longshoremen’s Ass’n, AFL-CIO (ILA I), 447 U.S. 490 (work‑preservation agreements: two‑part test including signatory’s right of control)
NLRB v. Int’l Longshoremen’s Ass’n, AFL-CIO (ILA II), 473 U.S. 61 (distinguishing primary vs. secondary agreements under § 8(e))
National Woodwork Manufacturers Ass’n v. NLRB, 386 U.S. 612 (§ 8(e) purpose: protect neutrals from union pressure)