Baria v. Singing River Elec Coop

CourtCourt of Appeals for the Fifth Circuit
DecidedMay 16, 2025
Docket20-60744
StatusUnpublished

This text of Baria v. Singing River Elec Coop (Baria v. Singing River Elec Coop) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Baria v. Singing River Elec Coop, (5th Cir. 2025).

Opinion

Case: 20-60744 Document: 58-1 Page: 1 Date Filed: 05/16/2025

United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit

____________ FILED May 16, 2025 No. 20-60744 Lyle W. Cayce ____________ Clerk

Barrett Baria; Edward Zielinski; Lorraine Zielinski, as named Plaintiffs representing a class of Mississippi citizens,

Plaintiffs—Appellants,

versus

Singing River Electric Cooperative, also known as Singing River Electric Power Association,

Defendant—Appellee. ______________________________

Appeal from the United States District Court for the Southern District of Mississippi USDC No. 1:19-CV-248 ______________________________

Before Richman, Graves, and Ho, Circuit Judges. Priscilla Richman, Circuit Judge: * Members of the Singing River Electric Cooperative sued the co-op (Singing River), claiming that it is obligated to return certain excess revenues to the members. Singing River moved to compel arbitration of these claims, but the district court denied the motion. Singing River then filed an interlocutory appeal in this court pursuant to 9 U.S.C. § 16(a). Singing River _____________________ * This opinion is not designated for publication. See 5th Cir. R. 47.5. Case: 20-60744 Document: 58-1 Page: 2 Date Filed: 05/16/2025

No. 20-60744

also moved to dismiss the members’ claims, and the district court granted the motion. The members now appeal the dismissal. Under the Supreme Court’s recent decision in Coinbase, Inc. v. Bielski, 1 the district court was required to stay its proceedings following the interlocutory appeal and should not have ruled on the motion to dismiss. We vacate the district court’s order. I Barrett Baria and the other plaintiffs (The Members) are current or former member-owners of the Singing River Electric Cooperative. Singing River is a non-profit electric power association operating pursuant to the Mississippi Electric Power Association Law. 2 Under § 235 of that law, “[r]evenues and receipts not needed” for statutorily approved purposes “shall be returned to the members by such means as the board may decide.” 3 The Members sued Singing River in Mississippi state court, alleging that Singing River failed to return certain excess revenues and receipts to The Members. Singing River removed the case to federal court and moved to compel arbitration pursuant to an arbitration provision in its bylaws. The district court initially granted Singing River’s motion to compel arbitration. Then, the court reversed course and granted The Members’ motion for reconsideration of the order granting the motion to compel. Singing River filed an appeal of the order granting the motion for reconsideration under 9 U.S.C. § 16(a)(1)(B), which “authorizes an

_____________________ 1 599 U.S. 736 (2023). 2 See Miss. Code Ann. § 77-5-201 et seq. (2016). 3 Id. § 77-5-235 (2016).

2 Case: 20-60744 Document: 58-1 Page: 3 Date Filed: 05/16/2025

interlocutory appeal from the denial of a motion to compel arbitration.” 4 That interlocutory appeal is pending before this court in a separate proceeding—Case No. 20-60312. After filing the interlocutory appeal, Singing River filed a motion in the district court to stay proceedings pending the appeal, and the district court deferred consideration of the motion. Singing River then filed a motion in the district court to dismiss The Members’ complaint, arguing that The Members had no vested right to Singing River’s capital and that Singing River’s board had discretion under Mississippi law to determine when to return excess revenues to members. The district court granted Singing River’s motion to dismiss and denied as moot the motion to stay the case pending appeal. The court concluded that § 235 did not “require [Singing River] to return such funds to its members in the manner [The Members] contend.” The Members then appealed the district court’s order granting the motion to dismiss. This is the appeal now before us. II Since the district court entered the order granting the motion to dismiss, there have been two major legal developments affecting this case. First, this court held in Harper v. Southern Pine Electric Cooperative 5 that to state a claim under § 235 of the Mississippi Electric Power Association Law, “plaintiffs must identify revenues beyond what is ‘needed’ for the purposes outlined in the statute—as determined by the board” and cannot state a claim

_____________________ 4 Coinbase, Inc., 599 U.S. at 739; 9 U.S.C. § 16(a)(1)(B) (“An appeal may be taken from . . . an order . . . denying a petition under section 4 of this title to order arbitration to proceed.”). 5 987 F.3d 417 (5th Cir. 2021).

3 Case: 20-60744 Document: 58-1 Page: 4 Date Filed: 05/16/2025

unless “the board deems that [excess] revenues are ‘not needed’ for other purposes.” 6 Second, the Supreme Court held in Coinbase that “a district court must stay its proceedings while the interlocutory appeal on arbitrability is ongoing.” 7 Under Coinbase, the interlocutory appeal in this case “divest[ed] the district court of its control” of the case, and the district court was required to stay the proceedings. 8 In Coinbase, “[t]he sole question before [the Supreme Court was] whether a district court must stay its proceedings while the interlocutory appeal on arbitrability is ongoing.” 9 The Court held that “[t]he answer is yes.” 10 The Court explained how an interlocutory appeal under 9 U.S.C. § 16(a)—the same provision under which Singing River appealed—“divests the district court of its control” 11 over the case: Section 16(a) does not say whether the district court proceedings must be stayed. But Congress enacted § 16(a) against a clear background principle prescribed by this Court’s precedents: An appeal, including an interlocutory appeal, “divests the district court of its control over those aspects of the case involved in the appeal.” . . . The Griggs 12 principle resolves this case. Because the question on appeal is whether the case belongs in arbitration or instead in the district court, the entire case is essentially “involved in the appeal.” . . . In

_____________________ 6 Id. at 423-24 (quoting Miss. Code Ann. § 77-5-235 (2016)). 7 Coinbase, Inc., 599 U.S. at 740. 8 Id. (quoting Griggs v. Provident Consumer Disc. Co., 459 U.S. 56, 58 (1982) (per curiam)). 9 Id. 10 Id. 11 Id. (quoting Griggs, 459 U.S. at 58). 12 Griggs v. Provident Consumer Disc. Co., 459 U.S. 56 (1982) (per curiam).

4 Case: 20-60744 Document: 58-1 Page: 5 Date Filed: 05/16/2025

short, Griggs dictates that the district court must stay its proceedings while the interlocutory appeal on arbitrability is ongoing.

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Firestone Tire & Rubber Co. v. Risjord
449 U.S. 368 (Supreme Court, 1981)
Griggs v. Provident Consumer Discount Co.
459 U.S. 56 (Supreme Court, 1982)
Marrese v. American Academy of Orthopaedic Surgeons
470 U.S. 373 (Supreme Court, 1985)
Harper v. Virginia Department of Taxation
509 U.S. 86 (Supreme Court, 1993)
Weingarten Realty Investors v. Miller
661 F.3d 904 (Fifth Circuit, 2011)
Charles Grant v. Kevin Houser
469 F. App'x 310 (Fifth Circuit, 2012)
Harper v. Southern Pine Electric
987 F.3d 417 (Fifth Circuit, 2021)
Coinbase, Inc. v. Bielski
599 U.S. 736 (Supreme Court, 2023)

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Baria v. Singing River Elec Coop, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baria-v-singing-river-elec-coop-ca5-2025.