A petition for a writ of mandamus was granted in In re: Ryse Claims Solutions, LLC, No. 19-2930 (7th Cir. August 3, 2020) because the District Court erred in transferring back to the Eastern California District Court a portion of plaintiff’s action arising out of an employment contract, where plaintiff alleged violations of the Fair Labor Standards Act, as well as various violations of the California Labor Code. The contract contained a forum-selection clause providing that the plaintiff must bring claims against defendant in either Indiana state court or Indiana federal court. The record showed that: (1) plaintiff had originally brought instant lawsuit in California state court; (2) defendant successfully removed action to United States District Court for the Eastern District of California, which granted defendant’s motion to transfer the case to the District Court of Southern Indiana based upon the forum selection clause; and (3) the District Court of Southern Indiana thereafter transferred a portion of case back to California.
The Seventh Circuit, in granting defendant’s petition for writ of mandamus, found that Southern Indiana District Court should have retained the entire lawsuit pursuant to the forum-selection clause, which, according to Appellate Court, should have been given controlling weight in all but most the exceptional cases. Moreover, the District Court of Southern Indiana improperly: (1) placed burden on defendant to justify keeping case in Indiana; (2) held a belief that transfer was warranted because the Eastern California District Court was more familiar with applicable California law; and (3) failed to acknowledge that delay in bringing instant case to trial was longer in California than in Indiana.