Luis Montoya Jr. v. Ariba Inc. et al.

Summary

The Central District of California denied Plaintiff Luis Montoya Jr.’s motion to remand, concluding that complete diversity jurisdiction existed because the defendants were Delaware corporations with their principal place of business in Pennsylvania. The court granted the defendants’ motion to transfer under 28 U.S.C. § 1404(a), enforcing a forum-selection clause requiring proceedings in Pennsylvania, and ordered transfer to the Eastern District of Pennsylvania.

Holdings

1. Complete diversity existed because plaintiff was a California citizen and defendants were Delaware corporations with their principal place of business in Pennsylvania; therefore, remand for lack of subject matter jurisdiction was unwarranted.
2. The forum-selection clause was not shown to be unreasonable because plaintiff did not establish fraud or overreaching, deprivation of his day in court, or contravention of a strong public policy.
3. Labor Code section 925 did not invalidate the forum-selection clause because plaintiff did not establish that signing the Global Incentive Plan was a condition of employment.
4. Transfer to the United States District Court for the Eastern District of Pennsylvania was appropriate under § 1404(a).

Questions Presented

1. Whether complete diversity existed so that removal was proper and remand was unwarranted.
2. Whether defendants' principal place of business was Pennsylvania rather than California under the corporate 'nerve center' test.
3. Whether the forum-selection clause in SAP's Global Incentive Plan was valid and enforceable.
4. Whether Labor Code section 925 barred enforcement of the forum-selection clause because the clause was allegedly a condition of employment.
5. Whether transfer to the Eastern District of Pennsylvania was appropriate under 28 U.S.C. § 1404(a).

Disposition

transferred