J.B. Hunt Transport, Inc. v. BNSF Railway Co., No. 20-2679 (8th Cir. 2021)
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After an arbitration panel issued its award in a dispute between J.B. Hunt and BNSF, the district court confirmed the award but denied Hunt's request for additional relief.
The Eighth Circuit focused on the substance of Hunt's request for additional relief rather than how Hunt captioned it, concluding that the request was not premature. The court also concluded that, assuming Hunt's interpretation of the award is correct, it was entitled to a declaratory judgment to that effect once the district court had confirmed the award. BNSF's argument to the contrary is unavailing. Although the court agreed with BNSF that it need not reach the merits of the parties' dispute about the interpretation of the award to conclude that the district court properly denied Hunt's request for "enforcement" insofar as it was a request for an order of specific performance, the court did not need to reach the merits of the parties' dispute about the interpretation of the award to determine whether the district court properly denied Hunt's request for "enforcement" insofar as it was a request for a declaratory judgment. Finally, the court concluded that the parties' arguments expose a genuine ambiguity in the award, describing BNSF's obligations under the award. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.
Court Description: [Gruender, Author, with Benton and Shepherd, Circuit Judges] Civil case - Arbitration. Hunt appeals the district court's denial of its request for additional relief in conjunction with the affirmance of an arbitration award; the request was not premature; in so far as the request amounted to a request for a declaratory judgment, by clarifying the meaning of the award, a declaratory judgment would give Hunt something the confirmation of the arbitration did not, and the request was not moot; nor was it precluded by 9 U.S.C. Sec. 11; in so far as the request for additional relief was a request for an order of specific performance, it was not moot, but it was precluded by the statute as the request amounted to a modification of the Arbitration Award; the parties' arguments expose a genuine ambiguity in the award; the court resolves the ambiguity and provides directions to the parties on calculating rates and revenues. Affirmed in part, reversed in part and remanded with directions for entry of a declaratory judgment consistent with the opinion.
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