Montoya v. CRST Expedited, Inc., 285 F. Supp. 3d 493

Plaintiff Juan Montoya, a former CRST driver, brought FLSA and Iowa-law wage claims as a putative collective action challenging unpaid wages and deductions arising from CRST's multi-phase training and pay system.
CRST required unpaid Phase 1 and Phase 2 training; trainees were later presented with a Pre-Employment Agreement (no forum clause) creating a $2,000+ repayment obligation for early termination, then an Employment Contract (signed later in Iowa) that included an Iowa choice-of-law and Cedar Rapids forum-selection clause.
Montoya alleges deductions, unlawful kickbacks, and excessive interest on training-related advances that reduce drivers below the federal minimum wage.
CRST moved to dismiss or transfer based on the forum-selection clause and, alternatively, under 28 U.S.C. § 1404(a); the court previously denied the motion without prejudice to consider Montoya’s language comprehension and the clause’s enforceability.
On renewed motion after discovery, the court declined to enforce the forum-selection clause because signing the contract in Iowa, after incurring a $2,000 debt and lacking a realistic opportunity to reject the contract, made enforcement unreasonable and unjust.
The court also denied transfer under § 1404(a), weighing plaintiff choice in an FLSA opt-in action, convenience (including CRST’s greater ability to bear litigation costs), document accessibility, and relative familiarity with Iowa law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Enforceability of forum-selection clause	Montoya lacked meaningful opportunity to reject clause; enforcing it would be unreasonable and unjust	Language proficiency irrelevant; clause routinely enforced in FLSA cases; discovery shows Montoya understood English	Clause unenforceable: enforcement would be unreasonable and unjust given the circumstances of signing and preexisting debt
Standard of review for clause after discovery	Motion must be treated under Rule 56 where extrinsic evidence exists	Court may conduct fact-finding similar to personal-jurisdiction inquiries	Court did not need to resolve conversion question because undisputed facts support the result under either standard
Effect of FLSA "opt-in" collective action on forum choice deference	Plaintiff: opt-in plaintiffs' choice of forum deserves substantial deference	Defendant: plaintiff's forum choice entitled to little weight because class is nationwide	Court gives considerable deference to plaintiff's forum choice in FLSA opt-in collective action; favors plaintiff
Transfer under § 1404(a) absent enforceable clause	Transfer is not warranted: plaintiff choice, witnesses include opt-ins, and defendant can absorb costs	Transfer to Northern District of Iowa is more convenient (witnesses, records, company location)	§ 1404(a) factors weigh against transfer overall; motion to transfer denied

Atl. Marine Constr. Co. v. U.S. Dist. Court for W. Dist. of Tex., 571 U.S. 49 (2013) (forum-selection clauses are normally enforced through § 1404(a) transfer analysis)
M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972) (forum-selection clauses prima facie valid; defenses include fraud, unreasonableness, impracticability, or contravention of public policy)
Soto v. State Indus. Prod., Inc., 642 F.3d 67 (1st Cir. 2011) (one ignorant of contract language may still be bound absent negligence; context matters)
Claudio-De Leon v. Sistema Univ. Ana G. Mendez, 775 F.3d 41 (1st Cir. 2014) (forum-selection clause enforcement framework and interaction with Rule 12(b)(6))
Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585 (1991) (forum-selection clauses subject to scrutiny for fundamental fairness in adhesion-like contexts)
Johnson v. VCG Holding Corp., 767 F. Supp. 2d 208 (D. Me. 2011) (FLSA opt-in mechanism supports deference to plaintiffs' forum choice)
Metcalf v. Bay Ferries Ltd., 937 F. Supp. 2d 147 (D. Mass. 2013) (declining to enforce forum clause where passengers lacked reasonable opportunity to learn terms)