Fourth Circuit Applies Supreme Court’s Coinbase Decision Outside Context of Arbitration

The Fourth Circuit Court of Appeals recently concluded that the U.S. Supreme Court’s decision in Coinbase Inc. v. Bielski is not limited to interlocutory appeals involving arbitration.

In Coinbase, which involved an interlocutory appeal from an order denying a motion to enforce an arbitration provision, the Supreme Court held that an interlocutory appeal of a motion denying arbitration “divests the district court of its control over those aspects of the case involved in the appeal.”

In City of Martinsville v. Express Scripts Inc., the city of Martinsville, Virginia, sued Express Scripts and OptumRx in state court related to their purported role in the opioid epidemic. The defendants removed the case to federal court, but the federal court remanded the case to state court. Immediately after the federal court remanded the case, but before the federal clerk mailed the remand order to the state court, Express Scripts filed an interlocutory appeal and sought to stay the case pursuant to Coinbase.

The district court denied the motion to stay, holding that Coinbase concerned appeals from motions regarding arbitration, not appeals regarding remand decisions. The Fourth Circuit reversed. It held that although Coinbase involved arbitration, that was a distinction without a difference and that Coinbase establishes that an automatic stay is in effect when appeals are filed regardless of whether the appeal concerns an order regarding arbitration, a remand order, etc. The court noted that while the stay may not preclude the court from taking any action whatsoever on the case, it precludes the court from taking action “over those aspects of the case involved in the appeal.” In the case of an appeal challenging a remand order, that includes mailing the remand order to the state court.

City of Martinsville v. Express Scripts Inc., No. 24-1912 (4th Cir. Feb. 10, 2025).