Garcia v. Roadrunner Transportation Services, Inc.

Background

Julian Garcia alleged that Roadrunner Transportation Services, Inc. and Roadrunner Transportation Systems, Inc. misclassified delivery drivers as independent contractors rather than employees. Garcia worked as a delivery driver for Roadrunner from approximately 2004 or 2005 through May 2017. He filed a proposed class action asserting claims for reimbursement of business expenses and violations of California’s Unfair Competition Law. Roadrunner removed the case from California state court under the Class Action Fairness Act.

Roadrunner moved under 28 U.S.C. § 1404(a) to transfer the case to the Eastern District of Wisconsin. The motion relied on forum-selection clauses in three independent-contractor agreements between Garcia and Roadrunner. Each agreement stated that Wisconsin law governed the agreement and that any action pertaining to it had to be brought exclusively in courts located in Milwaukee County, Wisconsin.

Court’s Analysis

The court interpreted the phrase “pertaining thereto” to mean “pertaining to the Agreement,” not merely pertaining to the agreement’s interpretation or performance. The court reasoned that the agreement itself was the subject of the sentence and that the parties had provided no indication that they intended different forums for different types of claims.

The court applied the meaning of “relating to,” which covers disputes having a logical or causal connection to the parties’ agreement. It concluded that Garcia’s misclassification claims fell within the forum-selection clause because they related to his agreements with Roadrunner.

The court then considered whether enforcing the clause would be unreasonable. It rejected Garcia’s argument that he had been shown only signature pages and told he had to sign to continue working, explaining that those allegations challenged the contract as a whole rather than the inclusion of the forum-selection clause itself. The court also rejected arguments based on Garcia’s business experience and education, stating that differences in power or education do not invalidate a forum-selection clause.

The court further rejected Garcia’s argument that transfer could deprive him of rights under the California Labor Code. It found that this argument depended on speculation about what substantive law the Wisconsin court would apply and did not show that transfer would violate a strong California public policy. The court also rejected Garcia’s argument that travel to Wisconsin would cause significant physical and financial stress, because agreeing to the clause waived objections that the selected forum was inconvenient.

Finally, the court found that Garcia had not identified public-interest factors that would make the case an exceptional one in which transfer should be denied despite a valid forum-selection clause.

Disposition

The court granted the motion to transfer and ordered the action transferred to the United States District Court for the Eastern District of Wisconsin. The order did not decide the merits of Garcia’s misclassification, expense-reimbursement, or unfair-competition claims. Judge Maxine M. Chesney signed the order.