Agreements on where to sue
Atlantic Marine Construction v. United States District Court for the Western District of Texas
In brief
The Court unanimously overturned the Fifth Circuit’s ruling and said courts should move cases to the contract-selected forum unless extraordinary circumstances unrelated to convenience clearly weigh against transfer.
- Where it stands
- Decided
Decided 9-0 · December 3, 2013 · Opinion by Justice Alito
- What it’s about
- The Court unanimously overturned the Fifth Circuit’s ruling and sent the case back to the lower court (remanded).
- Who it affects
- When a defendant asks a federal court to enforce a contract clause choosing where a case must be heard, the court should move the case unless extraordinary factors unrelated to the parties’ convenience clearly weigh against it.
Summary: written with AI from the case record.
What it's about
It ruled that a court can enforce a contract clause choosing where a lawsuit must be heard by transferring the case, and should do so unless extraordinary circumstances unrelated to the parties’ convenience clearly weigh against transfer.
Federal law lets a district court move a civil case to a district where it could have been filed or to a district all parties agreed to.
Question presented
1. 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)? 2. If so, who has the burden of proof when a party seeks to enforce or avoid a forum selection clause?
What the Court decided
Holding
1. A forum-selection clause may be enforced by a motion to transfer under §1404(a), which provides that “[f]or the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought or to any district or division to which all parties have consented.” 2. When a defendant files a §1404(a) motion, a district court should transfer the case unless extraordinary circumstances unrelated to the convenience of the parties clearly disfavor a transfer. No such exceptional factors appear to be present in this case. 701 F. 3d 736, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court said §1404(a) lets a defendant ask to move a case to a court allowed by the statute. Judges should honor the agreed forum unless extraordinary circumstances unrelated to party convenience clearly weigh against transfer; the Court found no such circumstances here.
The vote
What's next
The case returns to the Fifth Circuit, which must apply the Supreme Court’s transfer standard.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Opinion added: Atlantic Marine
More questions
- Who has to show that a case should not be transferred?
- The party opposing transfer must show extraordinary circumstances unrelated to the parties’ convenience that clearly weigh against it.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.