Jessica Mayhew v. Abbott Laboratories, Inc.

Summary

The United States District Court for the District of Maine considers Abbott Laboratories, Inc.’s motion to dismiss or transfer an employee’s claims under the ADA, MHRA, and MWPA based on an employment-agreement forum-selection clause. The court dismisses the MWPA claim without prejudice based on the plaintiff’s non-opposition and analyzes whether the remaining claims should be transferred to the Northern District of Illinois under 28 U.S.C. § 1404(a). The court also addresses the enforceability and scope of the forum-selection clause and the plaintiff’s challenges to the underlying agreement.

Holdings

1. The plaintiff's non-opposition constituted a voluntary dismissal of the MWPA claim, and Count IV was dismissed without prejudice.
2. The employee agreement was enforceable for purposes of the forum-selection clause because Mayhew assented electronically, and the agreement was not rendered illusory by Abbott's reservation-of-rights provision.
3. The agreement's forum-selection clause was mandatory and covered Mayhew's ADA and MHRA claims.
4. The forum-selection clause was not unenforceable merely because it appeared in an adhesive, nonnegotiated employment contract or because litigating in Illinois would be more burdensome for the plaintiff.
5. The ADA's special venue provision did not preclude enforcement of the forum-selection clause or transfer to the Northern District of Illinois where that district was a statutorily permissible venue.
6. The remaining ADA and MHRA claims were transferred to the Northern District of Illinois under § 1404(a).

Questions Presented

1. Whether Mayhew's non-opposition to dismissal of her MWPA claim warranted dismissal of that claim without prejudice.
2. Whether the employee agreement was sufficiently valid and enforceable for purposes of enforcing its forum-selection clause.
3. Whether the forum-selection clause was mandatory and encompassed Mayhew's ADA and MHRA claims.
4. Whether enforcement of the clause should be denied because of adhesion, alleged inconvenience, or the ADA's special venue provision.
5. Whether the remaining claims should be transferred to the Northern District of Illinois under 28 U.S.C. § 1404(a).

Disposition

other