Blackhawk Coal Sales, LLC v. XCoal Energy & Resources, et al.

CourtDistrict Court, S.D. West Virginia
DecidedApril 27, 2026
Docket2:25-cv-00492
StatusUnknown

This text of Blackhawk Coal Sales, LLC v. XCoal Energy & Resources, et al. (Blackhawk Coal Sales, LLC v. XCoal Energy & Resources, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Blackhawk Coal Sales, LLC v. XCoal Energy & Resources, et al., (S.D.W. Va. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

CHARLESTON DIVISION

BLACKHAWK COAL SALES, LLC,

Plaintiff,

v. CIVIL ACTION NO. 2:25-cv-00492

XCOAL ENERGY & RESOURCES, et al.,

Defendants.

MEMORANDUM OPINION AND ORDER

Pending before the Court is a Partial Motion to Dismiss filed by Defendants XCoal Energy & Resources (“XCoal”), XCoal Energy & Resources, LLC (“XCoal LLC”), and Ernie Thrasher (“Thrasher”) (collectively, “Defendants”). (ECF No. 10.) For the reasons discussed herein, the motion is GRANTED IN PART and DENIED IN PART. I. BACKGROUND This matter arises out of a contract dispute. (See ECF No. 1.) According to the Complaint, Defendant XCoal contracted to buy coal from Plaintiff Blackhawk Coal Sales, LLC (“Plaintiff”). (Id. at 2, ¶ 3.) However, Defendant XCoal allegedly did not pay for the coal that Plaintiff delivered. (Id., ¶ 4.) Consequently, Plaintiff initiated this lawsuit against Defendant XCoal. (See generally id.) Defendant XCoal LLC, which is purportedly the “general partner of XCoal and generally liable for its debts and obligations,” (id. at 2–3, ¶ 9), was also named as a defendant. Defendant

1 Thrasher, who is the “founder, president, [principal owner,] and Chief Executive Officer” of Defendant XCoal and the “organizer and managing member of XCoal LLC,” (id. at 3, ¶ 10), was also named as a defendant. According to the Complaint, Defendant “Thrasher approved, directed, and/or caused [Defendant] XCoal to enter into . . . the [c]ontracts,” even though he “knew or had reason to know that [Defendant] XCoal would never meet its payment obligations.” (Id. at 4, ¶

14; id. at 13, ¶ 76 (claiming that Defendant Thrasher did so to “serv[e] his interests”).) The Complaint asserts four claims. Count I is a claim for breach of contract asserted against Defendant XCoal. (Id. at 10–11.) Count II asserts a claim for Breach of the Implied Covenant of Good Faith and Fair Dealing against Defendant XCoal. (Id. at 11–12.) Count III asserts a claim for Unjust Enrichment against Defendant XCoal. (Id. at 12–13.) Count IV, titled “Alter Ego Liability,” attempts to pierce the corporate veil to hold Defendants Thrasher and XCoal LLC liable for Counts I, II, and III. (Id. at 13–14; see also ECF No. 12 at 6.) Count IV is premised on the allegation that Defendant Thrasher “controlled, dominated, managed, and operated” Defendants XCoal and XCoal LLC “as alter egos” to the point that Defendants’

“separateness ceased to exist.” (ECF No. 1 at 13, ¶ 77 (also claiming that Defendant XCoal is “insolvent” and “inadequately capitalized,” cannot pay its debts, and “lacks the capital to continue operating”).) Defendants filed the pending partial motion to dismiss on October 10, 2026. (ECF No. 10.) Plaintiff filed a response, (ECF No. 12), and Defendants filed a reply, (ECF No. 13). As such, this matter is fully briefed and ripe for adjudication. II. LEGAL STANDARD A motion to dismiss for failure to state a claim upon which relief may be granted tests the

2 legal sufficiency of a civil complaint. Fed. R. Civ. P. 12(b)(6). A plaintiff must allege sufficient facts, which, if proven, would entitle him to relief under a cognizable legal claim. Bell Atl. Corp. v. Twombly, 550 U.S. 544, 554–55 (2007). A case should be dismissed if, viewing the well- pleaded factual allegations in the complaint as true and in the light most favorable to the plaintiff, the complaint does not contain “enough facts to state a claim to relief that is plausible on its face.”

Id. at 570. In applying this standard, a court must utilize a two-pronged approach. First, it must separate the legal conclusions in the complaint from the factual allegations. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Second, assuming the truth of only the factual allegations, the court must determine whether the plaintiff’s complaint permits a reasonable inference that “the defendant is liable for the misconduct alleged.” Id. Well-pleaded factual allegations are required; labels, conclusions, and a “formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555; see also King v. Rubenstein, 825 F.3d 206, 214 (4th Cir. 2016) (“Bare legal conclusions ‘are not entitled to the assumption of truth’ and are insufficient to state a claim.” (quoting Iqbal, 556 U.S. at 679)). A plaintiff’s “[f]actual allegations must be

enough to raise a right to relief above the speculative level,” thereby “nudg[ing] [the] claims across the line from conceivable to plausible.” Twombly, 550 U.S. at 555, 570. III. DISCUSSION In the pending motion, Defendants seek dismissal of Counts II, III, and IV of the Complaint. (ECF No. 10, 11.) Each cause of action is discussed in turn below. A. Counts II and III As discussed above, Count II asserts a claim for Breach of the Implied Covenant of Good Faith and Fair Dealing, and Count III asserts a claim for Unjust Enrichment. In the pending

3 motion, Defendants argue that both of these claims must be dismissed because they are duplicative of Plaintiff’s breach of contract claim and cannot be maintained as a separate cause of action. (ECF No. 11 at 5–7.) Conversely, Plaintiff contends that it is permitted to assert these claims in the alternative at this point in litigation. (ECF No. 12 at 3–5.) The Court agrees with Plaintiff. Although the parties go to great lengths discussing New York state law,1 this issue is

governed by the Federal Rules of Civil Procedure. See Berk v. Choy, 607 U.S. ----, 146 S. Ct. 546, 552, 223 L. Ed. 2d 463 (2026) (explaining that “a valid Rule of Civil Procedure displaces contrary state law even if the state law would qualify as substantive under Erie’s test” (citing Hanna v. Plumer, 380 U.S. 460, 469–474 (1965))). “Analyzing whether a Federal Rule displaces state law is straightforward.” Id. The Court simply asks whether the Federal Rule “answers the question in dispute.” Id. (internal citations omitted). If so, the Federal Rule “governs, unless it exceeds statutory authorization or Congress’s rulemaking power.” Id. at 552–53 (internal quotations and citations omitted). In this case, the question is whether Plaintiff’s claims for breach of the implied covenant

of good faith and fair dealing and unjust enrichment must be dismissed as duplicative of the breach of contract claim. Rule 8 gives the answer. It provides that “[a] party may set out 2 or more statements of a claim or defense alternatively or hypothetically, either in a single count or defense or in separate ones.” Fed. R. Civ. P. 8(d)(2); see also Fed. R. Civ. P. 8(d)(3) (explaining that “[a] party may state as many separate claims or defenses as it has, regardless of consistency”). By permitting alternative and even inconsistent claims to be pleaded, Rule 8 establishes “implicitly,

1 The parties agree that New York substantive law governs the contract and quasi contract claims pursuant to the choice of law provision in the Contracts. (See ECF Nos. 11 at 3–4; 12 at 3.)

4 but with unmistakable clarity,” Hanna, 380 U.S. at 470, that a party may allege both contract and quasi-contract causes of action.

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Adrian King, Jr. v. Jim Rubenstein
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Blackhawk Coal Sales, LLC v. XCoal Energy & Resources, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/blackhawk-coal-sales-llc-v-xcoal-energy-resources-et-al-wvsd-2026.