Corpus: 543,223 opinions · 3,177 judges · newest 2026-06-23 · expanding Coverage ↗
Opinion

govinfo:USCOURTS-wvnd-1_24-cv-00099-1

U.S. District Court for the Northern District of West Virginia · 2026-03-31

· GavelSight synced 2026-09-06 03:50:24

IN THE UNITED STATES DISTRICT COURT  
FOR THE NORTHERN DISTRICT OF WEST VIRGINIA 
CLARKSBURG 
 
PERRY B. GAINS, 
 
  Plaintiff, 
 
v.       CIVIL ACTION NO. 1:24-CV-99 
         (KLEEH) 
 
ANTERO RESOURCES CORPORATION et al., 
 
  Defendants. 
 
MEMORANDUM OPINION AND ORDER GRANTING DEFENDANT ANTERO’S MOTION 
TO COMPEL ARBITRATION [ECF NO. 43] 
Pending before the Court is Antero Resources Corporation’s 
Motion to Compel Arbitration and Stay this Action [ECF No. 43]. 
For the reasons stated herein, the Motion [ECF No. 43] is GRANTED. 
I. PROCEDURAL BACKGROUND 
 
Plaintiff Perry B. Gains (“Plaintiff” or “Gains”) filed a 
Complaint in the Circuit Court of Doddridge County, West Virginia 
on September 12, 2024. ECF No. 1.  Defendants Antero Resources 
Corporation (“Antero”), Elaine S. Hunter, Lawrence L. Marshall, 
Thomas F. Menzel, Margaret D. Marshall Estate, Marjorie Smith, and 
Mary Ann Taylor (collectively “Defendants”) removed the case to 
this Court on October 17, 2024.  Id.  
Plaintiff alleges five causes of action: Count I: Conversion 
– Defendant Antero; Count II: Quiet Title/Declaratory Judgment – 
Defendant Antero and all Necessary/Indispensable Parties; Count 
III: Unjust Enrichment – Defendant Antero; Count IV: Trespass – 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 1 of 18  PageID #:
<pageID>
2 
 
Defendant Antero; and Count V: Waste – Defendant Antero. ECF No. 
1-1. 
Antero filed the subject Motion to Compel Arbitration and Stay 
Litigation on June 18, 2025. ECF No. 43.  On the same day, Antero 
filed a Motion for Leave to Amend Its Answer and Assert a 
Counterclaim. ECF No. 44.  Antero’s basis for filing a Motion to 
Amend was that it obtained a “Working Agreement” which contained 
an arbitration clause that allegedly bound the parties. ECF No. 
44.  On July 9, 2025, Gains filed Responses in Opposition to the 
Motion for Leave and to Compel Arbitration. ECF No. 48, 49. On 
July 16, 2025, Antero filed a Reply to Gains’ Response to the 
Motion for Leave and to Compel Arbitration. ECF No. 53, 54. The 
motion to compel arbitration is fully briefed and ripe for review. 
II. FACTUAL BACKROUND 
 
The following facts are from Plaintiff’s State Court 
Complaint. This case arises out of alleged improper and wrongful 
conduct related to the extraction and sale of oil and hydrocarbons 
from an Estate.  Specifically, the “common practice in Doddridge 
County in the early 1900s of . . . splitting the oil and gas 
estates into separate entities . . . for the purpose of development 
and operation.” Compl., ECF No. 1-1, at ¶ 17.  
Plaintiff Gains owns all rights to the Marcellus Shale oil 
leasehold in Doddridge County, West Virginia, which covers 
approximately 85 acres. Id. at ¶ 9.  Gains alleges that he recently 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 2 of 18  PageID #:
<pageID>
3 
 
discovered Defendant Antero “is currently pooling, developing and 
exploiting the Estate . . . and that the Defendant has been 
unlawfully selling oil and related hydrocarbons from the Estate.” 
Id. at ¶ 10.  Defendant Antero is a producer of natural gas and 
oil and operates wells in West Virginia. Id. at ¶ 3.  All other 
Defendants are the owners of the oil fee estate at issue and have 
been receiving oil royalties from Mr. Gains for years. Id. at ¶ 3. 
Gains is the successor in interest/current owner of the 
entirety of the oil Estate, but the oil and gas estates were split 
into two separate estates in the early 1900s. Id. at ¶ 13-14, ex. 
4.  Gains alleges that because Antero “had, and has, actual and 
constructive knowledge” of this common practice, Antero had a duty 
to investigate Mr. Gains’ ownership of the Estate. Id. at ¶ 18. 
Furthermore, because Gains ownership of the Estate is publicly 
available, Antero must have had an actual and constructive notice 
of such ownership. Id. at ¶ 19.  Therefore, Antero allegedly had 
knowledge that its chain of title was defective and “does not 
qualify as a bona fide purchaser at value.” Id. at ¶ 20-21.  
According to the Complaint, Antero has continued operating and 
producing the Estate with “actual, constructive, and record notice 
that Mr. Gains owns the Estate.” Id. at ¶ 26.  
A. Antero’s Motion to Compel Arbitration [ECF No. 43] 
The following facts are taken from Defendant Antero’s Motion 
to Compel Arbitration, its Memorandum in Support of the Motion, 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 3 of 18  PageID #:
<pageID>
4 
 
and its Motion for Leave to Amend its Answer and Assert a 
Counterclaim.  
The Motion to Compel Arbitration was filed after Antero 
allegedly discovered, during discovery, a working agreement 
entered into by the parties’ predecessors in interest. ECF No. 44, 
at 1.  Antero asserts that “Antero and Plaintiff are both lessees 
under a single Subject Lease—Antero is the lessee of the gas and 
gas leasehold, and Plaintiff is the lessee of the oil and oil 
leasehold. ECF No. 43-1, at 1.  
On October 19, 1908, the J.S. and Jane Netzer leased the oil 
and gas rights to their property to Hope Gas for a term of 10 
years. Id. at 2.  On July 18, 1918, before the expiration of the 
lease, the Netzers and Hope Gas signed another lease that was 
effective as a renewal on the day the original lease expired. Id. 
at 2-3.  On December 5, 1918, while the first lease was still in 
effect, Hope Gas assigned its oil leasehold and development rights 
to Carter Oil. Id. at 3.  This created two separate lessees and 
leasehold estates under the Subject Lease. Id.  
Especially relevant to Antero’s Motion to Compel Arbitration 
is that under the Hope-Carter Agreement, Hope Gas and Carter Oil 
“entered into the Working Agreement, which governed the parties’ 
rights and responsibilities with respect to conducting operations 
on their respective leasehold estates under the Subject Lease.” 
Id. at 1.  This Working Agreement contains a mandatory arbitration 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 4 of 18  PageID #:
<pageID>
5 
 
clause. Id. at 5.  In addition, the Hope-Carter agreement expressly 
states that the Subject Lease is subject to preexisting working 
agreements. Id. at 3.   
On February 26, 2025, Carter Oil assigned its rights in the 
Subject Lease, the oil rights it received from the Hope-Carter 
Assignment, to C.H. Pigott. Id. at 4.  The Carter-Pigott assignment 
provided that “the oil and oil rights in the Subject Lease were 
conveyed from Hope Gas to Carter Oil by the Hope-Carter 
Assignment[,]” and the agreement stated “that the said lease and 
leasehold estates are subject to a working agreement between 
[Carter and Hope Gas.]” Id. at 4.  In addition, the Working 
Agreement states in relevant part that the “agreement is intended 
by the companies to be continuing and will, hereafter, by reference 
merely, be applied to other leases or gas or gas rights thereunder 
which the Oil Company may from time-to-time assign to the Gas 
Company.” Id. at 5.  Antero claims that this Working Agreement 
governs the dispute at issue in this case because Antero and 
Plaintiffs are successors in interest to Hope Gas and Carter Oil. 
Id.  
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 5 of 18  PageID #:
<pageID>
6 
 
III. LEGAL STANDARD 
 
A. Federal Arbitration Act (9 U.S.C. §§ 2, 3) 
The Federal Arbitration Act (“FAA”) outlines the “procedures 
for enforcing arbitration agreements in federal court.”  Smith v. 
Spizzirri, 601 U.S. 472, 473 (2024).  Section 2 of the FAA states: 
A written provision in any maritime 
transaction or a contract evidencing a 
transaction involving commerce to settle by 
arbitration a controversy thereafter arising 
out of such contract or transaction, or the 
refusal to perform the whole or any part 
thereof, or an agreement in writing to submit 
to arbitration an existing controversy arising 
out of such a contract, transaction, or 
refusal, shall be valid, irrevocable, and 
enforceable, save upon such grounds as exist 
at law or in equity for the revocation of any 
contract or as otherwise provided in chapter 
4. 
 
9 U.S.C.A. § 2.  The Fourth Circuit holds, “a litigant can compel 
arbitration under the FAA if he can demonstrate: ‘(1) the existence 
of a dispute between the parties, (2) a written agreement that 
includes an arbitration provision which purports to cover the 
dispute, (3) the relationship of the transaction, which is 
evidenced by the agreement, to interstate or foreign commerce, and 
(4) the failure, neglect or refusal of the defendant to arbitrate 
the dispute.’”  Adkins v. Labor Ready. Inc., 303 F.3d 496, 500-
501 (4th Cir. 2002). Additionally, section 3 of the FAA sets forth 
that: 
If any suit or proceeding be brought in any of 
the courts of the United States upon any issue 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 6 of 18  PageID #:
<pageID>
7 
 
referable to arbitration under an agreement in 
writing for such arbitration, the court in 
which such suit is pending, upon being 
satisfied the issue involved in such suit or 
proceeding is referable to arbitration under 
such an agreement, shall on application of one 
of the parties stay the trial of the action 
until such arbitration has been had in 
accordance with the terms of the agreement, 
providing the applicant for the stay is not in 
default in proceeding with such arbitration.  
 
9 U.S.C. § 3.  
B. West Virginia State Contract Law 
“Although federal law governs the arbitrability of disputes, 
ordinary state-law principles resolve issues regarding the 
formation of contracts.”  Lawhun v. CMH Homes, Inc., No. 1:22-CV-
112, 2023 WL 5280909, at *5 (N.D. W.Va. Aug. 16, 2023) (internal 
citation omitted); see In re Cotton Yarn Antitrust Litig., 505 
F.3d 274 (4th Cir. 2007)(“State contract law govern the question 
of whether the parties have agreed to arbitrate....”). 
Therefore, questions regarding incorporation by reference of 
writings are governed by State contract law. The Supreme Court of 
Appeals of West Virginia holds that a three-pronged test must be 
satisfied for incorporation by reference to apply: 
In the law of contracts, parties may 
incorporate by reference separate writings 
together into one agreement. However, a 
general reference in one writing to another 
document is not sufficient to incorporate that 
other document into a final agreement. To 
uphold the validity of terms in a document 
incorporated by reference, (1) the writing 
must make a clear reference to the other 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 7 of 18  PageID #:
<pageID>
8 
 
document so that the parties’ assent to the 
reference is unmistakable; (2) the writing 
must describe the other document in such terms 
that its identity may be ascertained beyond 
doubt; and (3) it must be certain that the 
parties to the agreement had knowledge of and 
assented to the incorporated document so that 
the incorporation will not result in surprise 
or hardship.  
 
Syl. Pt. 2, State ex rel. U-Haul Co. of W. Virginia v. Zakaib, 232 
W. Va. 432 (2013).  
IV. DISCUSSION 
Defendant Antero sets forth that the arbitration clause 
contained in the Working Agreement discussed above governs this 
dispute and arbitration is therefore mandatory under the FAA.  
Plaintiff contends that the Working Agreement does not bind the 
parties before the court and compulsory arbitration, along with a 
stay, is not mandatory.  In addition, Plaintiff argues that if the 
parties are subject to the arbitration clause, Antero has waived 
its right to arbitrate.  For the reasons discussed below, the Court 
GRANTS Antero Resources Corporation’s Motion to Compel Arbitration 
and Stay this Action [ECF No. 43] 
A. The Court GRANTS Antero’s Motion to Compel Arbitration because 
the Fourth Circuit’s Adkins factors for compulsory arbitration 
under the Federal Arbitration Act are met.  
Section 2 of the FAA sets forth that 
 [a] written provision in . . . a contract 
evidencing a transaction involving commerce to 
settle by arbitration a controversy thereafter 
arising out of such contract or transaction, 
. . . or an agreement in writing to submit to 
arbitration an existing controversy arising 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 8 of 18  PageID #:
<pageID>
9 
 
out of such a contract, transaction, or 
refusal, shall be valid, irrevocable, and 
enforceable, save upon such grounds as exist 
at law or in equity for the revocation of any 
contract or as otherwise provided in chapter 
4. 
 
9 U.S.C.A. § 2.  The “party seeking to enforce the arbitration 
agreement, bears the initial burden” of demonstrating to the court 
that the parties entered into an enforceable arbitration 
agreement. Little v. Cellco P'ship, 304 F. Supp. 3d 508, 510 
(S.D.W. Va. 2018).  To satisfy this burden, and compel arbitration 
under Section 2, a litigant must: 
demonstrate: ‘(1) the existence of a dispute 
between the parties, (2) a written agreement 
that includes an arbitration provision which 
purports to cover the dispute, (3) the 
relationship of the transaction, which is 
evidenced by the agreement, to interstate or 
foreign commerce, and (4) the failure, neglect 
or refusal of the defendant to arbitrate the 
dispute.’ 
 
Adkins v. Labor Ready. Inc., 303 F.3d 496, 500-501 (4th Cir. 2002).   
As a threshold matter, all four of the factors outlined in 
Adkins are met. Therefore, as discussed further in Section B, if 
incorporation by reference of the Working Agreement is proper under 
West Virginia contract law, the Court is inclined to compel 
arbitration.  First, there is clearly a dispute between the parties 
as evidenced by the filing of the Complaint. See Frashuer v. Altice 
USA, Inc., No. 2:21-CV-17, 2023 WL 195523, at *3 (N.D. W. Va. Jan. 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 9 of 18  PageID #:
<pageID>
10 
 
17, 2023) (holding that the plaintiff’s complaint was sufficient 
evidence of a dispute between the parties).  
Second, there is an arbitration provision contained in the 
Working Agreement which, on its face, binds the parties.  The 
Working Agreement between Hope Gas and Carter Oil applied to the 
Subject Lease.  Both the Hope-Carter Assignment and the Carter-
Piggott Assignment, which Plaintiff is the successor in interest 
to, expressly state that the Subject Lease is subject to the 
Working Agreement.  Therefore, Antero and Plaintiff are successor 
lessees to the Subject Lease and Working Agreement.  Thus, the 
parties before the Court are subject to the Working Agreement and 
bound by the arbitration clause contained therein.1  Lastly, the 
third and fourth Adkins factors are satisfied.  The dispute between 
Antero and Plaintiff involves interstate commerce because 
materials produced from the Subject Lease are sold outside of West 
Virginia.  In addition, factor four is satisfied because Plaintiff 
has refused to submit the dispute to arbitration. Accordingly, if 
under West Virginia contract law the Working Agreement was properly 
 
1 Plaintiff further suggests in his Response that Antero’s well 
permitting activity, specifically that “it permitted the well/horizontal 
legs pursuant to the July 16, 1918, Lease Agreement, . . . not pursuant 
to prior, unspecified working agreements” means the working agreement 
was “terminated on its face by operation.” However, the document Antero 
is required to complete during the permitting stages (WW-6A1 Form) does 
not request disclosure of any contracts associated with the land. Failing 
to disclose the Working Agreement during the permitting stage is not 
relevant to the incorporation of the Working Agreement into the 1918 
Hope-Carter assignment and subsequent assignments.  
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 10 of 18  PageID #:
<pageID>
11 
 
incorporated by reference, the Motion to Compel Arbitration should 
be granted. 
B. Under West Virginia contract law, the arbitration agreement 
applies because the references to the Working Agreement satisfy 
the U-Haul incorporation by reference standard.  
Where a defendant successfully demonstrates that the parties 
entered into an agreement to arbitrate, “the burden shifts to the 
plaintiff to show that even though there was some written contract, 
[they] did not actually agree to it” for a “reason evincing lack 
of true agreement.” Little, at *10.  Whether a writing, separate 
from a signed contract between the parties, can be validly 
incorporated by reference, is a question of State contract law.  
See Lawhun, at *5; see also Helly v. TriEnergy, Inc., 877 F.Supp.2d 
414, 423-24 (N.D.W. Va. 2012) (explaining that the “one important 
caveat to the reach of the FAA” is that state law governs the 
formation of the contract).  
The Supreme Court of Appeals of West Virginia holds that an 
exacting three-pronged test must be satisfied for incorporation by 
reference to apply:  
In the law of contracts, parties may 
incorporate by reference separate writings 
together into one agreement.  However, a 
general reference in one writing to another 
document is not sufficient to incorporate that 
other document into a final agreement.  To 
uphold the validity of terms in a document 
incorporated by reference, (1) the writing 
must make a clear reference to the other 
document so that the parties’ assent to the 
reference is unmistakable; (2) the writing 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 11 of 18  PageID #:
<pageID>
12 
 
must describe the other document in such terms 
that its identity may be ascertained beyond 
doubt; and (3) it must be certain that the 
parties to the agreement had knowledge of and 
assented to the incorporated document so that 
the incorporation will not result in surprise 
or hardship.  
Syl. Pt. 2, State ex rel. U-Haul Co. of W. Virginia v. Zakaib, 232 
W. Va. 432 (2013).  
In U-Haul, the Court dealt with the common law doctrine of 
incorporation by reference in the context of two documents. Id. at 
435.  First, the rental contract that was signed by plaintiffs 
which contained a provision stating that “the plaintiffs agreed to 
the terms of the Addendum.”  Id.  Second, was the “Rental Contract 
Addendum” which U-Haul attempted to incorporate by reference into 
the rental contract. Id.  The addendum contained an arbitration 
clause. Id.  In holding the addendum was not incorporated by 
reference, the Court reasoned that the “electronic contracts 
succinctly referenc[ing]” the Addendum was “not a sufficient 
reference to the Addendum[.]” Id. at 444.  In addition, the 
reference was “quite general” and provided “no detail” to ensure 
those signing the rental agreement were aware of the addendum and 
its terms. Id.  Furthermore, U-Haul had a practice of supplying 
the addendum to customers, “only after the Rental Agreement had 
been executed[,]” and it designed the addendum to “look more like 
a document folder advertising U-Haul products . . . rather than a 
legally binding contractual agreement.” Id.   
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 12 of 18  PageID #:
<pageID>
13 
 
Here, Plaintiff contends that Antero cannot satisfy the U-Haul 
standard for several reasons.  First, “Antero cannot identify . . 
. the specific ‘working agreements’ that apply to the Netzer 
leasehold estates described in the December 5, 1918, Assignment of 
Leases[,]” and this is evidenced by the omission of descriptive 
information, “such as the dates of the agreements, recording 
information and/or instrument numbers.”  ECF No. 49, at 10. In 
large part, the lack of a date accompanying the description of the 
Working Agreement in the 1918 Hope-Carter Assignment is the basis 
for this contention (the 1918 Hope-Carter Assignment states: 
“subject to the terms of the working agreements dated the ____ day 
of _____ A.D. 19____”). Id.  In addition, Antero has allegedly 
failed to show how the Working Agreements apply to the December 5, 
1918 Assignment of Leases, what the terms of the working agreements 
are, and “how this issue is capable of being resolved ‘beyond 
doubt’ when the December 5, 1918 Assignment of Leases is general 
in nature, with no detail/specify being set forth on the face of 
the instrument, or any indication that arbitration has any 
relationship to the 1918 Assignment of Leases.”  Id.  
Despite the absence of precise specificity in the assignments, 
these arguments are unavailing.  First, although dates or other 
descriptive information are missing in the December 18, 1918, Hope-
Carter Assignment to identify the Working Agreement, the 
Assignment clearly states: 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 13 of 18  PageID #:
<pageID>
14 
 
[s]aid lands were heretofore embraced in 
leases for oil and gas purposes in which the 
The Carter Oil Company owned the leasehold oil 
rights, and the Hope Natural Gas Company owned 
the leasehold gas rights under and subject to 
the terms of the working agreement[.] 
ECF No. 43, ex. C, at 3.  The Working Agreement referred to in 
this excerpt of the Hope-Carter Assignment is clearly the agreement 
that Hope Gas and Carter Oil entered in anticipation of the 1918 
Assignment.  ECF No. 43, ex. E.  Similarly, the subsequent Carter-
Pigott assignment on February 26, 1925, states that gas rights are 
to remain with Hope Gas, “and that the said lease and leasehold 
estate are subject to a working agreement between The Carter Oil 
Company and the Hope Natural Gas Company[.]” ECF No. 43, ex. D, at 
1.  Therefore, the identity of the Working Agreement referred to 
by the Hope-Carter Assignment, and then the Carter-Pigott 
Assignment, is hardly in doubt.  These clear references to the 
Working Agreement in the assignments make the parties’ assent to 
it unmistakable.   
Next, Working Agreement plainly sets forth how it applies to 
the 1918 Assignment and its terms. ECF No. 43, ex. E.  Lastly, 
Plaintiff suggests that this case is “highly analogous” to U-Haul 
because Antero seeks to incorporate “an unspecified 1911 working 
agreement into a subsequent Assignment of Leases executed in 1918.”  
ECF No. 49, at 9.  However, largely for the same reasons above, 
this argument falls short. Unlike U-Haul, the parties to each 
assignment were given more than a succinct reference to the Working 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 14 of 18  PageID #:
<pageID>
15 
 
Agreement.  Both assignments provided the necessary details 
because they explicitly stated that the singular Working Agreement 
entered into by Hope Gas and Carter Oil would govern the parties 
moving forward.  Additionally, there was no effort by any party to 
conceal the Working Agreement until the assignments had been 
executed.  
Accordingly, the three-pronged U-Haul test for incorporation 
by reference is satisfied.  Under the Working Agreement, there is 
an agreement to arbitrate that binds the parties before the court. 
Thus, unless Antero waived its right to arbitrate, this matter 
should be arbitrated pursuant to Sections 2 and 3 of the Federal 
Arbitration Act. 
C. Antero has not waived its right to arbitrate because the time 
between its discovery of the Working Agreement, and it seeking 
to compel arbitration, is not sufficient to constitute waiver.  
“Nothing in the Federal Arbitration Act, 9 U.S.C. § 2, 
overrides normal rules of contract interpretation.  Generally 
applicable contract defenses—such as . . . waiver . . . may be 
applied to invalidate an arbitration agreement.”  Syl. Pt. 3, 
Williams v. Tucker, 239 W.Va. 395 (2017).  Furthermore, under West 
Virginia contract law: 
[t]he common-law doctrine of waiver focuses on 
the conduct of the party against whom waiver 
is sought, and requires that party to have 
intentionally relinquished a known right. A 
waiver may be express or may be inferred from 
actions or conduct, but all of the attendant 
facts, taken together, must amount to an 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 15 of 18  PageID #:
<pageID>
16 
 
intentional relinquishment of a known right.  
There is no requirement of prejudice or 
detrimental reliance by the party asserting 
waiver.  
Id. at Syl. Pt. 5. 
The Fourth Circuit holds that “[a] party may waive its right 
to insist on arbitration if the party ‘so substantially utilize[es] 
the litigation machinery that to subsequently permit arbitration 
would prejudice the party opposing the stay.”  MicroStrategy, Inc. 
v. Lauricia, 268 F.3d 244, 249 (4th Cir. 2001) (explaining that 
“the dispositive question is whether the party objecting to 
arbitration has suffered actual prejudice.”).  Therefore, the 
party opposing arbitration based on waiver bears a “heavy burden.” 
Id. at 250 (“Neither delay nor the filing of pleadings . . . 
without more” is sufficient to constitute waiver.).   
This heavy burden is not overcome when, with knowledge of an 
applicable arbitration agreement, the proponent of such 
arbitration participates in litigation for over eight months, 
engages in discovery, participates in mediation, and has a motion 
decided before the court. Patten Grading & Paving, Inc. v. Skanska 
USA Bldg., Inc., 380 F.3d 200, 203, 205 (4th Cir. 2004) (explaining 
where discovery produced an agreement to arbitrate entered by the 
proponent’s successor in interest four months before arbitration 
was sought, that delay did not constitute waiver.).  Lastly, 
because of the “strong federal policy favoring arbitration” the 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 16 of 18  PageID #:
<pageID>
17 
 
Fourth Circuit “will not lightly infer the circumstances 
constituting a waiver.”  Am. Recovery Corp. v. Computerized Thermal 
Imaging, Inc., 96 F.3d 88, 95 (4th Cir. 1996).  
Here, Mr. Gains contends that Antero, through its active 
participation in litigation for an extended time, without raising 
arbitration as an affirmative defense, has waived its right to 
arbitrate. ECF No. 49, at 11-14.  According to Gains, Antero’s 
participation includes “multiple discovery requests, 
scheduling/confer conferences, and case development.” Id. at 13-
14.  However, like Patten, the delay between Antero’s discovery of 
the Working Agreement (February 27, 2025) that bound its successor 
in interest, and it moving to compel arbitration (June 18, 2025), 
was around four months.  Likewise, the time between the filing of 
the Complaint and Antero’s Motion to Compel Arbitration was roughly 
nine months (September 12, 2024, to June 18, 2025). Antero’s 
participation in litigation for this period does not rise to the 
level of substantial utilization of the litigation machinery. 
MicroStrategy, 268 F.3d at 249.  Thus, Plaintiff fails to meet the 
heavy burden of showing Antero waived its right to arbitrate.   
Accordingly, this Court declines to accept waiver as an 
applicable defense and GRANT Antero’s Motion to Compel Arbitration 
and Stay this Action [ECF No. 43].  
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 17 of 18  PageID #:
<pageID>
18 
 
V. CONCLUSION 
For the reasons discussed above, Antero Resources 
Corporation’s Motion to Compel Arbitration and Stay this Action 
[ECF No. 43] is GRANTED. The parties SHALL participate in 
arbitration. This action is thus DISMISSED without prejudice 
pending arbitration and STRICKEN from the Court’s active docket.2 
Any remaining pending motions are accordingly DENIED AS MOOT. 
It is so ORDERED. 
 The Clerk is hereby directed to transmit copies of this Order 
to counsel of record. 
 DATED: March 31, 2026      
 
      ____________________________ 
THOMAS S. KLEEH, CHIEF JUDGE 
NORTHERN DISTRICT OF WEST VIRGINIA 
 
 
2 “[D]ismissal is a proper remedy when all of the issues presented in a 
lawsuit are arbitrable.” Choice Hotels Int'l, Inc. v. BSR Tropicana 
Resort, Inc., 252 F.3d 707, 709–10 (4th Cir. 2001); Simmons v. TA 
Operating, LLC, 2023 WL 2759771, at *6 (S.D.W. Va. Mar. 31, 2023). 
 
 
 
 
Case 1:24-cv-00099-TSK     Document 65     Filed 03/31/26     Page 18 of 18  PageID #:
<pageID>

Passage view · GavelSight