Mims v. FedEx Corporation

Summary

The court transfers the plaintiff's ERISA action concerning denial of a hardship withdrawal from the Northern District of California to the Western District of Tennessee. The transfer is based on a forum-selection clause in the retirement plan, which the court enforces under Ninth Circuit precedent holding that ERISA does not bar such clauses.

Holdings

1. ERISA's permissive venue provision does not bar parties from agreeing in advance to litigate ERISA disputes in a specific federal forum; the Plan's forum-selection clause is enforceable.
2. The action must be transferred to the United States District Court for the Western District of Tennessee pursuant to the Plan's forum-selection provision.

Questions Presented

1. Whether the Plan's forum-selection clause is enforceable notwithstanding ERISA's venue provision.
2. Whether the case should be transferred to the United States District Court for the Western District of Tennessee.

Disposition

other