Atlantic Marine Construction v. US District Court

From wikilawschool.org. Wiki Law School does not provide legal advice. For educational purposes only.
Atlantic Marine Construction v. US District Court
Court Supreme Court of the United States
Citation
Date decided 2013-12-3
Appealed from 5th Circuit

Facts

Atlantic Marine Construction Co. ("AMC"), a Virginia corporation, contracted with the United States Army Corps of Engineers to build a childhood development center in Fort Hood, Texas.

AMC sub-contracted some of the work to J-Crew Management, a Texas corporation. The contract with J-Crew included a forum-selection clause for any litigation in either (1) the Norfolk, Virginia circuit court or (2) US District Court for the Eastern District of Virginia ( E.D. Va.).

Procedural History

Following a payment dispute, J-Crew sued AMC in US federal western district court of Texas.

AMC moved to dismiss the case, contending the wrong venue & improper under 28 U.S. Code ยง 1406(a). AMC loses.

Issues

Should a federal district court transfer a case to the federal venue designated by the parties in a valid forum-selection clause?

Holding

Yes. Section 1404(a) is the appropriate mechanism for enforcing a valid forum-selection clause & the clause should be enforced absent extraordinary circumstances.

Reasons

Samuel Alito: Trial courts normally consider both (1) convenience & (2) public interest in assessing a Section 1404(a) motion to transfer venue.

Rule

If the forum-selection clause points to a non-federal forum, the correct enforcement mechanism is the doctrine of forum non conveniens.

Resources