XTRA Lease, LLC v. Rideway Express, Inc.

Summary

The United States District Court for the Eastern District of Missouri grants XTRA Lease LLC’s motion to remand a diversity action removed by Rideway Express, Inc. The court holds that Rideway agreed to XTRA’s Standard Terms and Conditions through electronically accepted online terms and that the incorporated forum-selection clause required litigation in the Circuit Court of St. Louis County, Missouri. The case is remanded to that state court.

Holdings

1. XTRA established by undisputed evidence that Rideway agreed to XTRA's Standard Terms and Conditions through its president's electronic acceptance during the online credit-application and account-opening processes.
2. The valid forum-selection clause required remand because Rideway waived its right to remove the dispute to federal court.

Questions Presented

1. Whether Rideway and XTRA entered into a valid agreement incorporating XTRA's Standard Terms and Conditions.
2. Whether the incorporated forum-selection clause was enforceable and required remand based on Rideway's waiver of its right to remove.
3. Whether the dispute was sufficiently related to the account and agreements governed by the forum-selection clause.

Disposition

remanded