specialized kind of forum-selection clause (Texas) · Go Syfert
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specialized kind of forum-selection clause in Texas

11 Texas opinions name it 2 courts 2004–2024 1 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
Scherk v. Alberto-Culver Co.green
scotus · 1974 · cited in 9 Texas opinions naming this issue, 2004–2024
2 sentences

2024In resolving these disputes, courts are not only guided by federal law, but also by drawing analogies to arbitration case law, as such clauses are generally recognized as “a specialized kind of forum-selection clause.” Pinto Tech, 526 S.W.3d at 437 (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , (1974)); In re AIU Ins.

2019In resolving disputes, courts are not only guided by federal law, but also by drawing analogies to arbitration cases based on the recognition that clauses requiring arbitration are “a specialized kind of forum-selection clause.” Id. (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 (1974)); In re AIU Ins.

59
In Re AIU Insurance Co.green
tex · 2004 · cited in 4 Texas opinions naming this issue, 2014–2024
2 sentences

2017Co., 148 S.W.3d 109, 115 (Tex. 2004)); see also Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449, 2457 , 41 L.Ed.2d 270 (1974) (contractual agreement to arbitrate before a specified tribunal is, “in effect, a specialized kind of forum-selection clause”).

2014Co., 148 S.W.3d at 115 ; see also id. at 115 n. 28 (“ ‘An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause ....’”) (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974)); Deep Water Slender Wells, Ltd., 234 S.W.3d at 694 (“We see no reason that ... courts would not also apply arbitration law’s equitable theories for enforce *458 ment by a nonsignatory to non-arbitration forum-selection clauses.”). 2 II.

44
Rodriguez De Quijas v. Shearson/American Express, Inc.green
scotus · 1989 · cited in 2 Texas opinions naming this issue, 2007–2015
2 sentences

2015While Pennzoil involves arbitration clauses, it is common for courts to refer to arbitration case law in forum-selection clause issues, and “the Supreme Court of the United States has stated that an arbitration agreement is a specialized kind of forum-selection clause.” See Rodriguez de Quijas v. Shearson/American Exp., Inc., 490 U.S. 477 , 482–83 (1989).

2007See Rodriguez de Quijas *694 v. Shearson/American Exp., Inc., 490 U.S. 477, 482-83 , 109 S.Ct. 1917, 1921 , 104 L.Ed.2d 526 (1989).

12
In Re Golden Peanut Co., LLCgreen
tex · 2009 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017Cf. In re Golden Peanut Co., 298 S.W.3d 629, 631 (Tex. 2009) (orig. proceeding) ("[A]rbitration clauses are, ‘in effect, a specialized kind of forum-selection clause.’ ” (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974))); In re Int’l Profit Assocs., Inc., 274 S.W.3d 672, 677 (Tex. 2009) (orig. proceeding) ("[W]e have drawn analogies between forum-selection clauses arid arbitration clauses.”). .

11
In Re International Profit Associates, Inc.green
tex · 2009 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017Cf. In re Golden Peanut Co., 298 S.W.3d 629, 631 (Tex. 2009) (orig. proceeding) ("[A]rbitration clauses are, ‘in effect, a specialized kind of forum-selection clause.’ ” (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974))); In re Int’l Profit Assocs., Inc., 274 S.W.3d 672, 677 (Tex. 2009) (orig. proceeding) ("[W]e have drawn analogies between forum-selection clauses arid arbitration clauses.”). .

11
Deep Water Slender Wells, Ltd. v. Shell International Exploration & Production, Inc.green
texapp · 2007 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014Co., 148 S.W.3d at 115 ; see also id. at 115 n. 28 (“ ‘An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause ....’”) (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974)); Deep Water Slender Wells, Ltd., 234 S.W.3d at 694 (“We see no reason that ... courts would not also apply arbitration law’s equitable theories for enforce *458 ment by a nonsignatory to non-arbitration forum-selection clauses.”). 2 II.

11
Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc.green
scotus · 1985 · cited in 1 Texas opinions naming this issue, 2009–2009
2 sentences

2009See also Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 628 , 105 S.Ct. 3346 , 87 L.Ed.2d 444 (1985) (stating that, “[b]y agreeing to arbitrate a statutory claim, a party does not forgo the substantive rights afforded by the statute; it only submits to their resolution in an arbitral, rather than a judicial, forum”).

2009See also Mitsubishi Motors Corp. v. Soler Chrysler-Plymouth, Inc., 473 U.S. 614, 628 , 105 S.Ct. 3346 , 87 L.Ed.2d 444 (1985) (stating that, “[b]y agreeing to arbitrate a statutory claim, a party does not forgo the substantive rights afforded by the statute; it only submits to their resolution in an arbitral, rather than a judicial, forum”).

11
L & L Kempwood Associates, L.P. v. Omega Builders, Inc.green
tex · 1999 · cited in 1 Texas opinions naming this issue, 2004–2004
1 sentence

2004Edwards World Solutions Co., 87 S.W.3d 546, 551 (Tex.2002); In re L & L Kempwood Assoc., L.P., 9 S.W.3d 125, 128 (Tex.1999); In re La.

11
Vimar Seguros Y Reaseguros, S. A. v. M/V Sky Reefergreen
scotus · 1995 · cited in 1 Texas opinions naming this issue, 2004–2004
2 sentences

2004"An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause that posits not only the situs of suit but also the procedure to be used in resolving the dispute.” Scherk v. Alherto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974); see also Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 534 , 115 S.Ct. 2322 , 132 L.Ed.2d 462 (1995) (observing that arbitration provisions are a subset of forum-selection clauses). .

2004"An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause that posits not only the situs of suit but also the procedure to be used in resolving the dispute.” Scherk v. Alherto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974); see also Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 534 , 115 S.Ct. 2322 , 132 L.Ed.2d 462 (1995) (observing that arbitration provisions are a subset of forum-selection clauses). .

11
In Re J.D. Edwards World Solutions Co.green
tex · 2002 · cited in 1 Texas opinions naming this issue, 2004–2004
1 sentence

2004Edwards World Solutions Co., 87 S.W.3d 546, 551 (Tex.2002); In re L & L Kempwood Assoc., L.P., 9 S.W.3d 125, 128 (Tex.1999); In re La.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (2)

CaseCitedYears
Pinto Technology Ventures, L.P. v. Sheldon green
tex · 2017
2 sentences

2024In resolving these disputes, courts are not only guided by federal law, but also by drawing analogies to arbitration case law, as such clauses are generally recognized as “a specialized kind of forum-selection clause.” Pinto Tech, 526 S.W.3d at 437 (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , (1974)); In re AIU Ins.

2019In resolving disputes, courts are not only guided by federal law, but also by drawing analogies to arbitration cases based on the recognition that clauses requiring arbitration are “a specialized kind of forum-selection clause.” Id. (quoting Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 (1974)); In re AIU Ins.

22019–2024
The Bremen v. Zapata Off-Shore Co. red
scotus · 1972
2 sentences

2004CODE art. 21.42. [27] 407 U.S. at 12 , 92 S.Ct. 1907 . [28] "An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause that posits not only the situs of suit but also the procedure to be used in resolving the dispute." Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974); see also Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 534 , 115 S.Ct. 2322 , 132 L.Ed.2d 462 (1995) (observing that arbitration provisions are a subset of forum-selection clauses). [29] See, e.g., In re J.D.

2004CODE art. 21.42. [27] 407 U.S. at 12 , 92 S.Ct. 1907 . [28] "An agreement to arbitrate before a specified tribunal is, in effect, a specialized kind of forum-selection clause that posits not only the situs of suit but also the procedure to be used in resolving the dispute." Scherk v. Alberto-Culver Co., 417 U.S. 506, 519 , 94 S.Ct. 2449 , 41 L.Ed.2d 270 (1974); see also Vimar Seguros y Reaseguros, S.A. v. M/V Sky Reefer, 515 U.S. 528, 534 , 115 S.Ct. 2322 , 132 L.Ed.2d 462 (1995) (observing that arbitration provisions are a subset of forum-selection clauses). [29] See, e.g., In re J.D.

12004–2004

Where else courts name it

TX 11 (2004–2024) PA 4 (2025–2025) DE 3 (2013–2021) OK 2 (2014–2014) CO 2 (2011–2013) CA 2 (2022–2022) FL 2 (2006–2018) AZ 2 (2016–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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