Cynthia R. Hill v. Nexstar Media Group, Inc. and Nexstar Media Inc.

Summary

The court denied Cynthia R. Hill’s motion to remand, concluding that the arbitration award of $76,644.50 satisfied the amount-in-controversy requirement for diversity jurisdiction. The court held that the Employment Agreement’s Dallas County forum-selection clause applied to Hill’s action seeking to vacate the arbitration award and granted transfer to the Northern District of Texas, Dallas Division. The court also terminated a duplicative first-filed action without prejudice and denied related motions as moot.

Holdings

1. Costs already awarded in an underlying arbitration proceeding are not the federal diversity proceeding costs excluded by 28 U.S.C. § 1332(a) and may be included in calculating the amount in controversy in an action seeking to vacate the arbitration award.
2. The court had diversity jurisdiction because the arbitration award plaintiff sought to vacate totaled $76,644.50, exceeding the $75,000 jurisdictional threshold.
3. The Employment Agreement's forum-selection clause applied to Hill's action seeking to vacate the arbitration award because the agreement required arbitration of disputes related to the agreement or employment and designated Dallas County, Texas, as the exclusive venue for court proceedings outside arbitration.
4. Transfer to the Northern District of Texas, Dallas Division, was warranted because the parties agreed to a valid, mandatory forum-selection clause designating Dallas County, Texas, and no extraordinary circumstances justified denying enforcement.

Questions Presented

1. Whether the costs and attorney's fees included in the arbitration award count toward the amount in controversy for diversity jurisdiction under 28 U.S.C. § 1332(a).
2. Whether the court had diversity jurisdiction over an action seeking to vacate an arbitration award totaling $76,644.50.
3. Whether the Employment Agreement's forum-selection clause designating Dallas County, Texas, applied to an action seeking to vacate the arbitration award.
4. Whether transfer to the Northern District of Texas was warranted under 28 U.S.C. § 1404(a).

Disposition

other