Vaughn Boyd v. Deadwood Tobacco Co.
Split Score
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Case Summary
Disposition
Affirmed
The Eighth Circuit affirmed dismissal of trademark-infringement claims by Vaughn Boyd and Drew Estate against Deadwood Tobacco Company. The panel held the claims arose from a stock-purchase agreement containing a mandatory forum-selection clause requiring litigation in South Dakota state court, and the district court properly dismissed the federal action on forum-non-conveniens grounds to enforce that clause.
Circuit Split Identified
Legal Issue
What body of law governs interpretation (meaning, scope, and applicability) of a contractual forum-selection clause in federal litigation?
Circuit Positions
Interpretation of forum-selection clauses governed by federal common/contract law regardless of choice-of-law clause.
Interpretation governed by the substantive law designated in the contract’s choice-of-law clause; federal law governs enforceability.
Interpretation governed by ordinary state contract law (typically the law selected by the parties or supplied by forum rules); federal law governs enforceability.
Conflict Summary
The circuits disagree whether courts should apply (1) federal common/contract law, (2) the substantive law chosen in the contract’s choice-of-law clause, or (3) the forum state’s ordinary contract law when construing a forum-selection clause. The Eighth Circuit applies state contract law (ordinarily the law chosen by the parties), while other circuits apply either federal common law or the law named in the contract itself.