Atlantic Marine Construction Company v. U.S. District Court for the Western District of Texas (2013)
- Docket
- 12-929
- Decided
- 2013-01-01
Summary
Question: Did the Supreme Court's decision in Stewart Organization, Inc. v. Ricoh Corp. limit review of forum selection clauses to a discretionary, balancing-of-conveniences analysis under 28 U.S.C. § 1404(a) If so, who has the burden of proof when a party seeks to enforce or avoid a forum selection clause? Conclusion: Yes; the party acting in violation of the forum-selection clause. Justice Samuel A. Alito, Jr. delivered the opinion for the unanimous Court. The Court held that Section 1404 codified a doctrine of transfer that allowed cases to be transferred to a more convenient forum rather than being dismissed. Because both Section 1404 and the forum non conveniens doctrine from which it derives depend on a balancing-of-interests standard, courts should use that standard when evaluating claims under Section 1404. The Court also held that, when parties have agreed to a forum-selection clause, a court should transfer the case to that forum unless there are exceptional factors at work. Therefore, the party requesting the change of forum should bear the burden of proving that such a change is necessary.