As to Pittston's first argument, however, the Rycoline decision warrants granting Pittston's Motion for Reconsideration. Where, during the pendency of a motion for reconsideration, the Third Circuit Court of Appeals, or other court of binding authority, issues a decision that reasonably can be said to control the issue underlying the motion for reconsideration, a district court has a responsibility to review its own opinion in light of the Third Circuit decision; this review not only advances the policy of judicial economy, but is mandated by our judicial hierarchy. Upon reconsideration, the Court may determine the extent to which the newly-issued decision controls the issue and whether the court's prior ruling should be affirmed, vacated or modified.
Here, Rycoline can reasonably be said to control the issue imbedded in Pittston's Motion for Reconsideration -- whether the entire controversy doctrine may be applied prior to the entry of final judgment in the first filed action. Moreover, the Rycoline court's reliance on Kaselaan, an instructive, if not dispositive, state court opinion which this Court failed to discuss in the Summary Judgment Opinion and which Pittston argues this Court overlooked, see Pl.'s Motion for Reconsideration Reply Br. ("Reply Br.") at 5, supports granting Pittston's Motion for Reconsideration. See Florham Park, 680 F. Supp. at 162. As such, the Court will grant Pittston's Motion for Reconsideration and will reconsider the Summary Judgment Opinion in light of Pittston's first argument, as illuminated by Rycoline. The Court, thus, revisits whether the entire controversy doctrine may be applied to bar a second filed action before final judgment is entered in the first filed action.
II. Pittston's Motion for Reconsideration
As indicated above, Pittston initially moved for reconsideration without the benefit of Rycoline. In its pre-Rycoline brief, Pittston argues that the Court improperly expanded the entire controversy doctrine in three respects.
See Pl.'s Reconsideration Br. at 3-8. In light of Rycoline, however, the Court is disinclined to discuss the three arguments. Instead, the Court will focus on the parties' supplemental briefs, which address why this Court should or should not follow Rycoline.
At the outset, it is important to acknowledge that this Court is bound by controlling decisions of the Third Circuit. "It is, of course, patent that a district court does not have the discretion to disregard controlling precedent simply because it disagrees with the reasoning behind such precedent." Vujosevic v. Rafferty, 844 F.2d 1023, 1030 n.4 (3d Cir. 1988). A district court owes "blind fealty" to the precedent of a circuit court. See Finch v. Hercules, Inc., 865 F. Supp. 1104, 1120 (D. Del. 1994); accord Poulis v. State Farm Fire and Cas. Co., 747 F.2d 863, 867 (3d Cir. 1984). Thus, if this Court finds Rycoline to control the question at issue here, this Court has no alternative but to follow the precedential announcement of the Third Circuit.
Sedgwick asserts two reasons why Rycoline does not require this Court to vacate its prior application of the entire controversy doctrine.
A. Sedgwick's First Argument as to Why Rycoline Does Not Require Vacating the Summary Judgment Opinion
First, Sedgwick avers that Rycoline is not controlling because it is contradicted by existing case law; Sedgwick lists eight decisions where a court invoked the entire controversy doctrine when the first filed action was still pending.
See Def.'s Br. of the Issues Presented by the Rycoline Decision ("Def.'s Rycoline Br.") at 3 and n.2. In particular, Sedgwick exclaims that
the Rycoline decision is squarely contradicted (and therefore necessarily mooted as an authoritative interpretation of New Jersey law) by the February 26, 1997 decision of the New Jersey Supreme Court in Gelber v. Zito Partnership, 147 N.J. 561, 688 A.2d 1044 (1997), which was not cited in Rycoline, presumably because it was issued after briefing and argument in Rycoline.