Ramaco Resources, LLC v. Chubb INA Holdings, Inc.

CourtDistrict Court, S.D. West Virginia
DecidedMarch 24, 2025
Docket2:19-cv-00703
StatusUnknown

This text of Ramaco Resources, LLC v. Chubb INA Holdings, Inc. (Ramaco Resources, LLC v. Chubb INA Holdings, Inc.) 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
Ramaco Resources, LLC v. Chubb INA Holdings, Inc., (S.D.W. Va. 2025).

Opinion

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

CHARLESTON DIVISION

RAMACO RESOURCES, LLC,

Plaintiff,

v. Case No.: 2:19-cv-00703

FEDERAL INSURANCE COMPANY, and ACE AMERICAN INSURANCE COMPANY,

Defendants.

MEMORANDUM OPINION AND ORDER

Pending before the Court are Defendants’ Motion to Compel (concerning Defendants’ First Set of Combined Discovery Requests) and Second Motion to Compel (concerning Defendants’ Second Set of Combined Discovery Requests). (ECF Nos. 496, 500). Having fully considered the motions and the parties’ briefs, the Court GRANTS, in part, and DENIES, in part, the motions as follows. The parties shall bear their own costs and attorneys’ fees associated with the motions and any discovery compelled by this Order. I. Relevant Facts In November 2018, a coal silo at the Elk Creek Mining complex operated by Plaintiff Ramaco Resources, LLC (“Ramaco”), collapsed. Defendant Federal Insurance Company (“Federal”), which used Defendant ACE American Insurance Company for claims handling, denied Ramaco’s insurance claim for the losses. Ramaco sued Defendants for breach of contract and bad faith. The matter was tried before a jury in a 12-day bifurcated trial. In the first phase, the jury awarded Ramaco $7.6 million in contract damages and prejudgment interest. (ECF No. 405 at 3). In the second phase, the jury awarded Ramaco $25 million under West Virginia’s Hayseeds doctrine, which permits an insured party to claim consequential damages when it prevails after suing to collect on its insurance policy. (Id.).

After the trial, the District Court reduced Ramaco’s contract damages and interest to $1.8 million and rejected the Hayseeds damages as a matter of state law. (Id.) The District Court also conditionally granted a new trial on the Hayseeds damages, reasoning that—even if Hayseeds damages were theoretically permissible—the jury’s $25 million award was punitive and invalid. (Id.) Ramaco appealed to the United States Court of Appeals for the Fourth Circuit (“Fourth Circuit”), which reversed the district court’s reduction of contract damages and prejudgment interest because the insurance policy’s plain language and the trial evidence support the jury’s original $7.6 million award. (Id.) The Fourth Circuit reversed the District Court’s wholesale rejection of Hayseeds damages but affirmed its conditional grant of a new Hayseeds damages trial as the District Court reasonably concluded that the amount awarded was punitive. (Id.).

On remand, the District Court concluded that Ramaco had “waived its right to seek net economic loss damages incurred before the first trial,” but that it “did not waive its right to seek Hayseeds damages incurred as a result of any future delay by Federal in paying the amount due under the policy.” (ECF No. 442 at 13). Thus, the Court narrowed the scope of retrial to economic loss caused by Federal’s delay in payment between the date of the jury’s verdict on July 15, 2021, and the date that Federal paid Ramaco the contract damages on October 2, 2023. Ramaco is also claiming aggravation and inconvenience damages for the entire period from Federal’s denial of the insurance claim to Federal’s payment of the awarded damages on October 2, 2023. The Court authorized a “brief discovery period, limited to . . . damages for net economic loss caused by the delay in settlement as well as an award for aggravation and inconvenience incurred between July 15, 2021 and October 2, 2023.” (Id. at 15). As relevant to the pending discovery motions, Ramaco asserted in its September

2024 expert disclosures a theory concerning its net economic loss damages. According to Ramaco, Defendants’ denial of its insurance claim in 2019 caused it to halt development of a new coal mine termed the Eight Kay mine (formerly known as the Turkeypen mine) at the Elk Creek Complex. Ramaco claims that, if Defendants not denied the claim, the Eight Kay Mine would have been operating and generated nearly 500,000 tons of coal from July 15, 2021 to October 2, 2023. According to Ramaco’s expert, Ramaco suffered net economic loss of $38 million to $70 million due to the Eight Kay Mine not operating during that period. II. Relevant law Rule 26(b)(1) of the Federal Rules of Civil Procedure outlines the scope of discovery:

[U]nless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

Fed. R. Civ. P. 26(b)(1). “Relevancy under this rule has been broadly construed to encompass any possibility that the information sought may be relevant to the claim or defense of any party.” Becton, Dickinson & Co. v. BioMedomics, Inc., No. 5:20-CV-536- FL, 2021 WL 3864476, at *3 (E.D.N.C. Aug. 30, 2021) (citations omitted). Yet, even if seeking relevant information, the discovery request must be proportional to the needs of the case. Fed. R. Civ. P. 26(b)(1). Although Rule 26(b)(1)’s relevance inquiry does not, itself, pose a high bar, however, its proportionality requirement mandates consideration of multiple factors in

determining whether to allow discovery of even relevant information. The factors include: “the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Ceresini v. Gonzales, No. 3:21-CV-40, 2022 WL 628520, at *3 (N.D.W. Va. Mar. 3, 2022). Further, this Court holds that “fishing expeditions” which exceed the boundaries of the complaint and are purely based on unsupported speculation are improper. Philips N. Am. LLC v. Probo Med. LLC, No. 2:21-CV-00298, 2022 WL 17793491, at *3 (S.D.W. Va. Dec. 19, 2022) (citing Cuomo v. Clearing House Assn., LLC, 557 U.S. 519, 531 (2009) (“Judges are trusted to prevent ‘fishing expeditions or an undirected rummaging through

... records for evidence of some unknown wrongdoing.”)) A party dissatisfied with a discovery response or lack of response can move for an order compelling disclosure or discovery after conferring or attempting to confer with the party that submitted the response or failed to respond. Fed. R. Civ. P. 37(a). Importantly, the party resisting discovery, not the party seeking discovery, bears the burden of persuasion. Tinsley v. OneWest Bank, FSB, No. 3:13-CV-23241, 2014 WL 7005852, at *2 (S.D.W. Va. Dec. 10, 2014) (citations omitted). As such, conclusory and unsubstantiated allegations are simply insufficient to support discovery objections based on the grounds of annoyance, burdensomeness, oppression, or expense. Id. III.

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Related

Cuomo v. Clearing House Ass'n, LLC
557 U.S. 519 (Supreme Court, 2009)

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Bluebook (online)
Ramaco Resources, LLC v. Chubb INA Holdings, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramaco-resources-llc-v-chubb-ina-holdings-inc-wvsd-2025.