Holly v. Hilton Worldwide Holdings, Inc., et al.

Summary

The United States District Court for the Eastern District of Virginia granted Playa Management USA, LLC’s motion to dismiss claims arising from an injury at a Jamaican resort. The court held that the plaintiff’s signed guest registration card contained a mandatory and reasonable forum-selection clause requiring claims to be brought in Jamaica under Jamaican law. The dismissal was without prejudice, and the defendant’s motion to stay was denied as moot.

Holdings

1. The clause was mandatory because it required any incident, claim, or legal proceeding to be submitted to the exclusive jurisdiction of the Jamaican courts.
2. The forum-selection clause was prima facie valid and reasonable because Holly did not establish fraud or overreaching, deprivation of her day in court or a remedy, or a violation of public policy.
3. PMUSA could enforce the forum-selection clause even though it did not sign the guest-registration card because it was closely related to the dispute and it was foreseeable that it would be bound.
4. The court could dismiss based on the forum-selection clause without resolving PMUSA's alternative forum non conveniens and personal-jurisdiction arguments.

Questions Presented

1. Whether the guest-registration card contained a mandatory forum-selection clause requiring claims to be litigated in Jamaica.
2. Whether the forum-selection clause was unreasonable because it was allegedly nonnegotiated, inconvenient, deprived Holly of a remedy, or contravened public policy.
3. Whether PMUSA, a nonsignatory to the guest-registration agreement, could enforce the forum-selection clause.
4. Whether the action against PMUSA should be dismissed without reaching forum non conveniens or personal-jurisdiction arguments.

Disposition

dismissed