Peabody Holding Company, LLC v. United Mine Workers of America, International Union, No. 10-2134
Decided: January 11, 2012
Appellee United Mine Workers of America, International Union entered into a limited job-preference agreement with Peabody Coal Company, which also bound Peabody Coal’s parent company and the parent company’s subsidiaries. The Union submitted a grievance to an arbitrator, who determined that the dispute was arbitrable but deferred a ruling on the merits. Peabody Holding responded by seeking a declaratory judgment in federal court that the dispute is not arbitrable. The district court entered judgment in favor of the Union and held that the arbitrator correctly determined that the dispute was arbitrable, and, in the alternative, the dispute was arbitrable even if the arbitrator lacked authority to decide the arbitrability question. The Fourth Circuit Court of Appeals found that the court, not the arbitrator, must decide the initial question of arbitrability. However, the court held that Peabody Holding did not rebut the presumption in favor of arbitrability, and therefore, the parties must proceed to arbitration.
-Sara I. Salehi