Peabody Holding Company v. United Mine Workers of America, 815 F.3d 154

The Jobs MOU (2007) required preferential hiring by certain Peabody corporate-family entities; it contained an arbitration clause designating a Jobs Monitor whose decisions would be "final and binding."
Peabody Energy spun off Patriot in 2007–08; Peabody Coal moved to Patriot while Peabody Holding and Black Beauty remained with Peabody Energy, raising dispute whether the Jobs MOU still bound Peabody Holding/Black Beauty.
The Union submitted the dispute to the Jobs Monitor; the parties agreed to bifurcate proceedings into liability and, if needed, remedies phases; the Jobs Monitor decided liability for the Union but reserved remedial questions and retained jurisdiction to decide them later.
The Companies filed a Section 301 declaratory action in federal court seeking to vacate the liability ruling; the Union counterclaimed to enforce the award and moved to dismiss as premature under the complete arbitration rule.
The district court refused to dismiss, treated the liability ruling as final, and entered summary judgment enforcing the Jobs Monitor’s liability decision; the Companies appealed.
The Fourth Circuit asked and addressed whether judicial review under Section 301 is appropriate before the arbitrator completes both liability and remedial phases (the "complete arbitration rule").

Issue	Plaintiff's Argument (Companies)	Defendant's Argument (Union)	Held
Whether a federal court may review an arbitrator's liability ruling when the arbitrator reserved remedial questions and retained jurisdiction	Parties bifurcated liability and remedies; liability decision is "final" and therefore reviewable now	Complete arbitration rule requires withholding review until arbitrator resolves both liability and remedies; judicial involvement is premature	Court holds review was premature: under the complete arbitration rule, arbitrator must be allowed to decide remedial phase before court review
Whether the complete arbitration rule is a jurisdictional limitation or a prudential rule	Section 301 grants broad jurisdiction; the rule should not be treated as a strict jurisdictional bar	Complete arbitration rule is prudential, not jurisdictional, but nonetheless controls and counsels abstention	Court holds the rule is prudential (not strictly jurisdictional) but enforces it here for policy and efficiency reasons

Gen. Drivers Local Union No. 89 v. Riss & Co., 372 U.S. 517 (recognition that courts enforce collective-bargaining arbitration awards under §301)
Gateway Coal Co. v. United Mine Workers, 414 U.S. 368 (describing arbitration as substitute for industrial strife)
Granite Rock Co. v. Int'l Bhd. of Teamsters, 561 U.S. 287 (federal policy favoring arbitration)
Peabody Holding Co. v. United Mine Workers, 665 F.3d 96 (4th Cir.) (prior appellate ruling that the dispute was arbitrable)
Union Switch & Signal Div. v. United Elec. Workers, 900 F.2d 608 (3d Cir. 1990) (articulation of the complete arbitration rule)
Millmen Local 550 v. Wells Exterior Trim, 828 F.2d 1373 (9th Cir. 1987) (discussion of complete arbitration rule and limited exceptions)