Mims v. FedEx Corporation

Background

Satchidananda Mims participated in the FedEx Corporation Retirement Savings Plan. He alleged that FedEx Corporation and Vanguard Group, Inc. violated the Employee Retirement Income Security Act of 1974 (ERISA) by improperly denying his request for a hardship withdrawal.

FedEx moved to dismiss for failure to state a claim or to dismiss or transfer the case for improper venue. Vanguard moved to dismiss for failure to state a claim and for improper venue.

Forum-selection clause

The Plan stated that disputes arising under it must be submitted to the United States District Court for the Western District of Tennessee. It also stated that claimants consented to that court’s jurisdiction and waived objections that the venue was inconvenient or improper.

Mims did not dispute that the provision applied to his claims or that it required suit in the Western District of Tennessee. He argued that the provision should not be enforced because ERISA provides several venues for bringing a case.

Court’s reasoning

The court relied on Ninth Circuit precedent holding that ERISA’s provision allowing suit where the plan is administered, where the breach occurred, or where a defendant resides or may be found does not require those venues. The Ninth Circuit had held that ERISA does not prohibit parties from agreeing in advance to litigate disputes in a specific federal court.

The court concluded that Mims’s only argument against transfer was not persuasive. Because the Plan’s forum-selection clause applied and was enforceable, the court transferred the case rather than deciding the parties’ remaining arguments.

Disposition

The court granted FedEx’s motion to transfer the case to the United States District Court for the Western District of Tennessee. It made no determination on the remaining arguments and left them for the transferee court to decide. The Clerk was directed to close the file.