venue selection clause (California) · Go Syfert
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venue selection clause in California

8 California opinions name it 1 courts 2003–2026 3 in the last five years

The cases below were cited by California 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 (7)

CaseFollowedCited
Alexander v. Superior Courtgreen
calctapp · 2003 · cited in 3 California opinions naming this issue, 2004–2014
2 sentences

2014(See Alexander v. Superior Court (2003) 114 Cal.App.4th 723, 726-727 [“Forum means ‘[a] court or other judicial body; a place of jurisdiction. [Citation.] Venue is ‘[t]he county or other territory’ in which a case may be heard, i.e., the place from which the jury will be selected. [Citations.] Under state law, therefore, a venue selection clause is purely an intrastate issue involving the selection of a county in which to hold the trial.

2013(See Alexander, supra, 114 Cal.App.4th at p. 728 .) In assessing the validity of the venue selection clause before it, the Supreme Court adopted the reasoning of the Massachusetts Supreme Court, as follows: “ ‘The rules to determine in what courts and counties actions may be brought are fixed upon consideration of general convenience and expediency by general law; to allow them to be changed by the agreement of the parties would disturb the symmetry of the law, and interfere with such convenience.

23
Lu v. Dryclean-U.S.A. of California, Inc.green
calctapp · 1992 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024(See Brown v. USA Taekwondo (2021) 11 Cal.5th 204 , 209 [at the demurrer stage, the truth of the allegations in the complaint are assumed]; see also Lu v. Dryclean-U.S.A. of California, Inc. (1992) 11 Cal.App.4th 1490, 1494 [an unsigned agreement does not necessarily render a forum selection clause unenforceable].) We express no opinion on whether the Agreement is valid and enforceable, and if so, on what terms.

11
Animal Film, LLC v. D.E.J. Productions, Inc.green
calctapp · 2011 · cited in 1 California opinions naming this issue, 2024–2024
1 sentence

2024Productions, Inc. (2011) 193 Cal.App.4th 466, 471 (Animal Film) [“When, as here, no conflicting extrinsic evidence has been presented, the interpretation of a forum selection clause is a legal question that we review de novo.”].) A venue selection clause is “purely an intrastate issue involving the selection of a county in which to hold the trial.” (Alexander v. Superior Court 7 When granting Caydon’s motion to dismiss, the trial court apparently assumed, without deciding, the existence of the Agreement between the parties.

11
Dream Theater, Inc. v. Dream Theatergreen
calctapp · 2004 · cited in 1 California opinions naming this issue, 2015–2015
1 sentence

2015(See Dream Theater, Inc. v. Dream Theater (2004) 124 Cal.App.4th 547, 556 [venue provisions did not limit scope of arbitration clause].) 6 royalties or provide accurate accountings are matters relating to the Audit Clause and thus arbitrable.

11
In Re Great Lakes Dredge & Dock Co., L.L.C.green
texapp · 2008 · cited in 1 California opinions naming this issue, 2014–2014
1 sentence

2014By contrast, a forum selection clause usually chooses a court from among different states or nations. [Citation.]” (Fn. omitted.)]; In re Great Lakes Dredge & Dock Co. (Tex.Ct.App. 2008) 251 S.W.3d 68, 73-74 (Great Lakes Dredge) [“[A] ‘forum’-selection agreement is one that chooses another state or sovereign as the location for trial, whereas a ‘venue’-selection agreement chooses a particular county or court within that state or sovereign.”].) While forum selection clauses will be enforced unless doing so would be unreasonable, venue selection clauses are invalid in California to the extent th

11
Kennedy/Jenks Consultants, Inc. v. Superior Courtgreen
calctapp · 2000 · cited in 1 California opinions naming this issue, 2003–2003
2 sentences

2003(See Kennedy/Jenks Consultants, Inc. v. Superior Court (2000) 80 Cal.App.4th 948, 959-960 [ 95 Cal.Rptr.2d 817 ].) We begin by observing that this case involves a venue selection clause, not a forum selection clause.

2003(See Kennedy/Jenks Consultants, Inc. v. Superior Court (2000) 80 Cal.App.4th 948, 959-960 [ 95 Cal.Rptr.2d 817 ].) We begin by observing that this case involves a venue selection clause, not a forum selection clause.

11
Milliken v. Graygreen
calctapp · 1969 · cited in 1 California opinions naming this issue, 2003–2003
2 sentences

2003(Black’s Law Dict., supra, p. 1553, col. 2; and see Milliken v. Gray (1969) 276 Cal.App.2d 595, 600 [ 81 Cal.Rptr. 525 ].) Under state law, therefore, a venue selection clause is purely an intrastate issue involving the selection of a county in which to hold the trial. 4 By contrast, a forum selection clause usually chooses a court from among different states or nations.

2003(Black’s Law Dict., supra, p. 1553, col. 2; and see Milliken v. Gray (1969) 276 Cal.App.2d 595, 600 [ 81 Cal.Rptr. 525 ].) Under state law, therefore, a venue selection clause is purely an intrastate issue involving the selection of a county in which to hold the trial. 4 By contrast, a forum selection clause usually chooses a court from among different states or nations.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
General Acceptance Corp. v. Robinson green
cal · 1929
2 sentences

2013According to Battaglia, the Supreme Court’s opinion in General Acceptance, supra, 207 Cal. at page 288 has rendered all contractual venue selection clauses void as contrary to public policy in California.

2003(General Acceptance, supra, 207 Cal. at p. 286 .) The Supreme Court affirmed the trial court’s transfer, holding that the venue selection clause was void.

22003–2013
Battaglia Enterprises, Inc. v. Superior Court neutral
calctapp · 2013
2 sentences

2026But the parties’ venue selection clause does not establish that the default judgment is void. “[W]hen venue is proper in more than one county, a plaintiff has the choice of where to file the action from among the available options.” (Battaglia 4 Enterprises, Inc. v. Superior Court (2013) 215 Cal.App.4th 309, 313 .) Here, Respondents chose to file the lawsuit in Santa Barbara County presumably because the property that was the subject of the parties’ agreement is in Santa Maria, within that county.

2026But the parties’ venue selection clause does not establish that the default judgment is void. “[W]hen venue is proper in more than one county, a plaintiff has the choice of where to file the action from among the available options.” (Battaglia 4 Enterprises, Inc. v. Superior Court (2013) 215 Cal.App.4th 309, 313 .) Here, Respondents chose to file the lawsuit in Santa Barbara County presumably because the property that was the subject of the parties’ agreement is in Santa Maria, within that county.

12026–2026
Global Packaging, Inc. v. Superior Court green
calctapp · 2011
1 sentence

2023(Global Packaging, supra, 196 Cal.App.4th at p. 1632 .) The court explained that because the parties in that case could have expressly consented to personal jurisdiction—yet did not— the courts should not supply the missing term.

12023–2023
Nute v. Hamilton Mutual Insurance green
mass · 1856
1 sentence

2013Such contracts might be induced by considerations tending to bring the administration of justice into disrepute.’ ” (General Acceptance, supra, 207 Cal. at p. 289 , quoting Nute v. Hamilton Mutual Insurance Company (1856) 72 Mass. 174, 184 .) The court also noted with approval “the general statement that ‘jurisdiction of the court is beyond the agreement of the parties.’ [Citation.]” (General Acceptance, supra, 207 Cal. at p. 289 .) It is clear that the venue selection agreement at issue in General Acceptance attempted to set venue in a county that was impermissible under the statutory venue s

12013–2013
Smith, Valentino & Smith, Inc. v. Superior Court green
cal · 1976
2 sentences

2004By contrast, a forum selection clause usually chooses a court from among different states or nations." ( Ibid., fn. omitted.) The court noted that one of the grounds for the holding in General Acceptance is that "venue selection clauses disrupt the Legislature's statutory venue scheme." ( Alexander, supra, at p. 728 , 8 Cal.Rptr.3d 111 .) By contrast, forum selection clauses, as the court in Smith acknowledged, "`violate no such carefully conceived statutory patterns.'" ( Alexander, supra, at p. 731 , 8 Cal.Rptr.3d 111 , quoting Smith, supra, 17 Cal.3d at p. 495 , 131 Cal.Rptr. 374 , 551 P.2d

2004By contrast, a forum selection clause usually chooses a court from among different states or nations." ( Ibid., fn. omitted.) The court noted that one of the grounds for the holding in General Acceptance is that "venue selection clauses disrupt the Legislature's statutory venue scheme." ( Alexander, supra, at p. 728 , 8 Cal.Rptr.3d 111 .) By contrast, forum selection clauses, as the court in Smith acknowledged, "`violate no such carefully conceived statutory patterns.'" ( Alexander, supra, at p. 731 , 8 Cal.Rptr.3d 111 , quoting Smith, supra, 17 Cal.3d at p. 495 , 131 Cal.Rptr. 374 , 551 P.2d

12004–2004
The Bremen v. Zapata Off-Shore Co. red
scotus · 1972
2 sentences

2003(See e.g., The Bremen v. Zapata Off-Shore Co. (1972) 407 U.S. 1 [ 32 L.Ed.2d 513 , 92 S.Ct. 1907 ] (Bremen).) The following discussion incorporates this distinction.

2003(See e.g., The Bremen v. Zapata Off-Shore Co. (1972) 407 U.S. 1 [ 32 L.Ed.2d 513 , 92 S.Ct. 1907 ] (Bremen).) The following discussion incorporates this distinction.

12003–2003

Where else courts name it

FL 12 (2001–2025) NY 11 (2004–2025) TX 10 (2007–2026) CA 8 (2003–2026) PA 5 (2000–2025) OK 3 (2014–2014) NC 3 (2002–2016) OH 2 (2002–2008) AZ 2 (2016–2019) IN 2 (1992–2013)

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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