Peabody Holding Company v. United Mine Workers of America

Vacated and remanded by published opinion. Judge WILKINSON wrote the opinion, in which Judge SHEDD and Judge AGEE joined.

WILKINSON, Circuit Judge:

In this case we must decide when and under what circumstances courts should review a labor arbitrator’s decision. For the reasons given below, we hold that judicial involvement in the labor dispute in this case was premature. Under the complete arbitration rule, the arbitrator should have been given the opportunity to resolve both the liability and remedial phases of the dispute between the Companies and the Union before it moved to federal court.…