Lacross v. Knight Transportation, Inc., 95 F. Supp. 3d 1199

Plaintiffs Patrick La-Cross, Robert Lira, and Matthew Lofton (California-based long-haul drivers) sued Knight Transportation and Knight Truck & Trailer Sales alleging misclassification as independent contractors and multiple California wage-and-hour and PAGA claims.
Defendants are Arizona-based and the drivers had signed two agreements: an Independent Contractor Operating Agreement (ICOA) and a Tractor Lease Agreement (TLA), both containing forum-selection clauses designating Phoenix, Arizona.
Defendants moved to transfer venue under 28 U.S.C. § 1404(a) to the District of Arizona based on those forum-selection clauses; Plaintiffs did not dispute signing the agreements.
Plaintiffs argued the clauses were unreasonable (overreaching, deprivation of access to court due to cost, and contrary to California public policy) and that the clauses did not cover their statutory claims.
The district court applied Ninth Circuit and Supreme Court forum-selection law, concluded Plaintiffs had not met the heavy burden to avoid enforcement, found the ICOA clause broadly covers disputes “relating to” the contractual relationship, and granted transfer to the District of Arizona.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Enforceability of forum-selection clauses	Clauses resulted from overreaching, adhesion, lack of notice	Clauses were clear, conspicuous, and voluntarily signed	Court: Clauses not unenforceable for overreaching; conspicuous and presumptively valid
Whether transfer would deprive plaintiff of day in court	La-Cross lacks funds to litigate in Arizona, so enforcement is unjust	Plaintiffs waived convenience objections by agreeing to clause; financial burden is a private interest not considered under Atlantic Marine	Court: Financial hardship insufficient post-Atlantic Marine to avoid transfer
Public-policy defense (California law & PAGA)	Enforcing clauses with Arizona choice-of-law would deny California statutory rights and public interest in adjudicating PAGA claims	Federal courts can apply California law; forum clause affects venue not access to judicial remedies	Court: Public-policy argument fails; no total foreclosure of remedy in Arizona; PAGA and labor claims can be adjudicated in another federal forum
Scope of clauses — do they cover statutory wage claims?	Plaintiffs: labor-code claims fall outside clause scope	Defendants: ICOA covers any proceedings “relating to the relationship created by this Agreement,” which includes misclassification claims	Court: ICOA’s broad “relating to” language encompasses Plaintiffs’ claims; transfer required

M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972) (forum-selection clauses are presumptively valid absent strong showing they are unreasonable)
Scherk v. Alberto-Culver Co., 417 U.S. 506 (1974) (challenge must be specific to inclusion of clause, not merely to contract procurement)
Manetti-Farrow, Inc. v. Gucci Am., Inc., 858 F.2d 509 (9th Cir. 1988) (federal law governs validity of forum-selection clauses in diversity cases)
Atlantic Marine Constr. Co. v. U.S. Dist. Court for W. Dist. of Tex., 571 U.S. 49 (2013) (forum-selection clauses generally control; plaintiff bears heavy burden to show transfer inappropriate; private-interest factors ordinarily not considered)
Murphy v. Schneider Nat'l, Inc., 362 F.3d 1133 (9th Cir. 2004) (power or education differentials in non-negotiated contracts do not automatically invalidate forum-selection clauses)
Doe 1 v. AOL LLC, 552 F.3d 1077 (9th Cir. 2009) (forum-selection clause is presumptively valid; heavy burden to show unenforceable)
Cape Flattery Ltd. v. Titan Mar., LLC, 647 F.3d 914 (9th Cir. 2011) (distinguishes narrow “arising under” clauses from broader “relating to/in connection with” language for clause scope)
Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (forum-selection clause analysis governed by federal law in diversity cases)