Falcon Crest Holdings, LLC v. Centurion Investments, Inc., d/b/a AVMATS Jet Support

Summary

The United States District Court for the Eastern District of Missouri grants Defendant Centurion Investments, Inc.’s motion to dismiss under the doctrine of forum non conveniens. The court enforces a forum-selection clause in the parties’ Work Authorization designating the Circuit Court of St. Louis County, Missouri, and dismisses the action without prejudice. The court rejects Plaintiff Falcon Crest Holdings, LLC’s arguments that the clause was unconscionable or unreasonable.

Holdings

1. A valid forum-selection clause designating a state forum is enforced through forum non conveniens, and the clause in the Work Authorization was enforceable because Falcon Crest failed to show that it was unjust, unreasonable, fraudulent, overreaching, unexpected, or unconscionably unfair.
2. A contract of adhesion, disparity in bargaining power, or absence of negotiations does not alone make a forum-selection clause unconscionable or unenforceable.

Questions Presented

1. Whether the Work Authorization's forum-selection clause designating the Circuit Court of St. Louis County, Missouri, was enforceable under the doctrine of forum non conveniens.
2. Whether the alleged disparity in bargaining power, lack of negotiation, time pressure, and purported contract of adhesion rendered the forum-selection clause unconscionable, unjust, or unreasonable.
3. Whether the action should be dismissed without prejudice in favor of the contractually designated state-court forum.

Disposition

dismissed