Mateer v. Peloton Interactive, Inc.
- Lorna Schofield
- 1:22-cv-00740
- U.S. District Court · Southern District of New York
- 3
In Mateer v. Peloton, Judge Schofield converted Peloton’s dismissal motion into summary judgment proceedings about a forum-selection clause.
The order directly affected the plaintiffs, including Katharine Johnson, and Peloton Interactive, Inc. It required both sides to submit evidence and limited supplemental briefing concerning the Letter Agreement and its forum-selection clause.
What happened
In Mateer v. Peloton Interactive, Inc., Peloton asked the court to dismiss Katharine Johnson’s claims or transfer the case based on a forum-selection clause in a letter agreement. The plaintiffs filed a later amended complaint that did not mention the agreement.
The plaintiffs disputed the agreement’s authenticity. Because the court could not consider a disputed outside document when deciding a dismissal motion, it determined that the issue required a different procedure.
Judge Schofield ordered that the dismissal motion be converted into a motion for summary judgment on whether the forum-selection clause is enforceable. She gave the plaintiffs and Peloton deadlines to submit evidence and limited supplemental briefing about the agreement and its applicability to Johnson’s claims.
The detailed version
- Mateer v. Peloton Interactive, Inc. · No. 1:22-cv-00740
- Lorna Schofield
- Sept. 29, 2022
Background
Peloton moved under Federal Rule of Civil Procedure 12(b)(6) to dismiss Katharine Johnson’s claims. In the alternative, Peloton asked the court to transfer the case to the Eastern District of Pennsylvania under 28 U.S.C. § 1404. Peloton relied on a Letter Agreement between Johnson and Peloton that included a forum-selection clause.
After Peloton filed its motion, the plaintiffs filed a Second Amended Complaint. Although the amended complaint did not mention the Letter Agreement, the court explained that an agreement may still be considered on a motion to dismiss if it is integral to the complaint. The court also explained that the document’s authenticity and accuracy must not be disputed before it can be considered for that purpose.
Disputed Agreement and Conversion
The plaintiffs disputed the authenticity of the Letter Agreement and argued that it should be stricken for lack of authentication. Because the authenticity dispute prevented the court from resolving the motion to dismiss using the agreement, the court applied Federal Rule of Civil Procedure 12(d). That rule requires a motion to dismiss to be treated as a motion for summary judgment under Rule 56 when the court considers material outside the pleadings, provided the parties have a reasonable opportunity to present relevant evidence.
Order
The court ordered that Peloton’s motion to dismiss be converted to a motion for summary judgment on the enforceability of the forum-selection clause in the Letter Agreement between Johnson and Peloton. The court ordered the plaintiffs to file, by October 14, 2022, evidence and any supplemental briefing addressing the authenticity and applicability of the Letter Agreement to Johnson’s claims, with the combined submission limited to five double-spaced pages. Peloton was ordered to file, by October 21, 2022, any additional evidence beyond the Letter Agreement and related supplemental briefing, also limited to five double-spaced pages.
This order did not decide whether the forum-selection clause was enforceable, whether the Letter Agreement was authentic or applicable, whether Johnson’s claims should be dismissed, or whether the case should be transferred.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.