Manning v. Jayco, Inc.
2:21-cv-01387-MCE-CKD
E.D. Cal.Aug 29, 2022Background
- Plaintiff Tony Manning (California resident) bought a new 2020 Jayco Seneca RV on June 30, 2020 and alleges numerous, recurring defects beginning in August 2020.
- Plaintiff executed a warranty registration form dated June 26, 2020 (four days before the sales contract) representing he had received and read Jayco’s Limited Warranty.
- The Limited Warranty contains a mandatory forum-selection clause requiring warranty-related disputes be filed in Indiana courts and that Indiana law applies.
- Jayco moved to transfer the case to the Northern District of Indiana under 28 U.S.C. § 1404(a) based on that clause.
- Manning opposed, arguing the clause was procured by fraud/overreaching because the warranty allegedly was provided only after purchase and that litigating in Indiana would deprive him of his day in court.
- The court found no evidence supporting Manning’s fraud/overreaching claim (and noted the registration form predates the sales contract), rejected the convenience and public-policy arguments, held the forum-selection clause valid, and granted transfer to the Northern District of Indiana.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of forum-selection clause | Clause was procured by fraud/overreaching because warranty allegedly provided after sale | Warranty registration was signed (dated before sale) and clause is presumptively valid | Clause valid; plaintiff failed to rebut presumption of enforceability |
| Convenience / ability to litigate in Indiana | RV and witnesses located in California; RV cannot be moved; witnesses unwilling to travel | Transfer need not require moving RV; subpoenas (Rule 45) and discovery can proceed in CA; private convenience largely irrelevant when clause controls | Convenience arguments insufficient to defeat clause |
| Public policy / bad-faith selection of forum | Enforcement would be fundamentally unfair or chosen to deter claims | No evidence of bad faith or public-policy violation | No public-policy bar; enforcement does not contravene public interest |
Key Cases Cited
- Atlantic Marine Constr. Co. v. U.S. Dist. Court, 571 U.S. 49 (2013) (forum-selection clauses should be given controlling weight and govern § 1404(a) analysis)
- Stewart Org. v. Ricoh Corp., 487 U.S. 22 (1988) (forum-selection agreements reflect parties’ expectations and affect transfer analysis)
- M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972) (forum-selection clause unreasonable if result of fraud, undue influence, or defeats party’s day in court)
- Argueta v. Banco Mexicano, S.A., 87 F.3d 320 (9th Cir. 1996) (sets factors for when forum-selection clause is unreasonable)
- Celtic Int’l, LLC v. J.B. Hunt Transport, Inc., 234 F. Supp. 3d 1034 (E.D. Cal. 2017) (forum-selection clause is presumptively valid; plaintiff’s choice of forum carries no weight when clause valid)
- Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (transfer decisions under § 1404(a) are within district court’s discretion)