WASHINGTON FRONTIER LEAGUE BASEBALL, LLC v. FRONTIER PROFESSIONAL BASEBALL, INC.
2:16-cv-01556
W.D. Pa.Feb 13, 2017Background
- Washington Frontier League Baseball, LLC (the Wild Things) filed this action against Frontier Professional Baseball, Inc. arising from disputes over a proposed team acquisition and alleged failure to investigate other owners’ conduct.
- Plaintiff had earlier filed a related lawsuit (S.D. Ind.) and initiated arbitration in the Southern District of Indiana based on the League Bylaws’ arbitration clause specifying venue at the League Offices in Indianapolis.
- Defendant moved to dismiss for lack of subject-matter jurisdiction and for failure to state a claim, alternatively seeking a stay and to compel arbitration.
- Plaintiff argued federal jurisdiction was proper and relied on an S.D. Ind. decision interpreting the Bylaws and arbitration clause; the arbitration remains pending and raises claims identical to those in this suit.
- The district court evaluated transfer under 28 U.S.C. § 1404(a), applying the Jumara private and public factors and considering judicial economy, pending related litigation in S.D. Ind., and the parties’ prior submission to arbitration.
- The court concluded the Jumara factors strongly favored transfer and ordered the case transferred to the U.S. District Court for the Southern District of Indiana.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this court should retain or transfer the case under § 1404(a) | Plaintiff prefers W.D. Pa.; case filed where team is based | Transfer appropriate given related S.D. Ind. litigation/arbitration | Transfer to S.D. Ind. warranted under Jumara factors |
| Whether pending arbitration and arbitration clause preclude federal adjudication here | Court jurisdiction is proper despite arbitration; relied on S.D. Ind. interpretation | Arbitration pending and clause calls for Indianapolis; suit duplicative | Transfer to district where arbitration and related suit pending for consistency; arbitration favored |
| Whether plaintiff waived ability to challenge arbitrability by initiating arbitration | Plaintiff submitted claims to arbitration but claims judicial forum available | Defendant argues submission may waive challenge to arbitrability | Court found plaintiff may have waived arbitrability objection; S.D. Ind. should decide waiver |
| Convenience and judicial economy (private/public Jumara factors) | Local interest in Pittsburgh; plaintiff’s forum choice | Related proceedings, witnesses, and forum contacts favor Indiana | Private and public factors (including judicial economy) weigh strongly for transfer |
Key Cases Cited
- Jumara v. State Farm Ins. Co., 55 F.3d 873 (3d Cir.) (lists private and public factors for § 1404(a) transfer analysis)
- Harris v. Green Tree Fin. Corp., 183 F.3d 173 (3d Cir.) (federal policy favors enforcement of arbitration agreements)
- Lucey v. FedEx Ground Package Sys., Inc., [citation="305 F. App'x 875"] (3d Cir.) (voluntary submission to arbitration can waive judicial review)
- Econo-Car Intern., Inc. v. Antilles Car Rentals, Inc., 499 F.2d 1391 (3d Cir.) (district courts lack power to order arbitration to occur outside their district)
- Shaffer v. Graybill, [citation="68 F. App'x 374"] (3d Cir.) (district court must dismiss or transfer action to location of arbitration)
- United States v. Mitlo, 714 F.2d 294 (3d Cir.) (decisions of other district courts are persuasive but not binding)