2:17-cv-00871
W.D. Pa.Jul 31, 2017Background
- M&M Creative Laminates (M&M) and Cambria Company entered a supplier‑distributor relationship and executed a 2009 credit agreement containing a forum‑selection clause designating Le Sueur County, Minnesota.
- Cambria sued M&M in the U.S. District Court for the District of Minnesota (D. Minn. Civ. A. No. 17‑2463); M&M filed a related action in the Western District of Pennsylvania and sought a preliminary injunction to enjoin the Minnesota litigation.
- Cambria moved to transfer the Pennsylvania case to Minnesota under 28 U.S.C. § 1404(a); M&M amended its complaint but did not substantively oppose the transfer motion.
- M&M argued the forum‑selection clause was an adhesion contract or contrary to public policy and invoked the first‑filed rule to keep its Pennsylvania action prioritized.
- The Western District of Pennsylvania reviewed the parties’ agreement, the first‑filed rule, and Jumara/Atlantic Marine guidance on forum‑selection clauses and § 1404(a) transfers.
- The court concluded the forum‑selection clause was valid, no extraordinary circumstances justified ignoring it, and transfer to the District of Minnesota served judicial economy; it denied the injunction and ordered transfer to D. Minn.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to enjoin the Minnesota suit (preliminary injunction) | M&M sought to enjoin Cambria’s Minnesota suit and keep litigation in W.D. Pa. under first‑filed rule | Cambria argued forum clause requires disputes be adjudicated in Le Sueur County/Minnesota and injunction is inappropriate | Denied — no basis to enjoin; forum clause controls and first‑filed rule does not override it |
| Enforceability of forum‑selection clause | M&M claimed clause was adhesion/unenforceable or against public policy | Cambria asserted clause is valid and parties knowingly conducted business under it for years | Enforced — clause valid, not unconscionable, no extraordinary circumstances to set it aside |
| Transfer under 28 U.S.C. § 1404(a) to federal court in Minnesota | M&M implicitly preferred W.D. Pa.; raised first‑filed priority | Cambria sought transfer to D. Minn.; argued judicial economy and related pending Minnesota litigation favor transfer | Granted — case transferred to District of Minnesota and related to pending D. Minn. matter |
| Whether this court can transfer case to Minnesota state court | M&M removed to federal court and sought to proceed there; dispute over remand scope | Cambria sought state forum; court in Pennsylvania cannot transfer to state court | Court cannot transfer to state court; ordered federal transfer so D. Minn. can resolve whether remand is appropriate |
Key Cases Cited
- Atlantic Marine Const. Co., Inc. v. U.S. Dist. Court for W. Dist. of Texas, 134 S. Ct. 568 (2013) (valid forum‑selection clauses generally enforceable; plaintiff’s chosen forum given no weight)
- Jumara v. State Farm Ins. Co., 55 F.3d 873 (3d Cir. 1995) (factors to balance on § 1404(a) transfers include public and private interests)
- Salovaara v. Jackson Nat'l Life Ins. Co., 246 F.3d 289 (3d Cir. 2001) (district court cannot transfer a case to state court when parties agreed on a state forum)
- Chavez v. Dole Food Co., Inc., 836 F.3d 205 (3d Cir. 2016) (district court has discretion to transfer under the first‑filed rule and account for forum‑selection clauses)
- Todd Heller, Inc. v. United Parcel Service, Inc., 754 A.2d 689 (Pa. Super. Ct. 2000) (adhesion contract status alone does not render a forum clause unenforceable)