Appeal from the United States District Court for the Northern District of Ohio at Toledo.
No. 3:21-cv-02336—Jack Zouhary, District Judge.
Argued: October 18, 2023
Decided and Filed: April 12, 2024
Before: BATCHELDER, GRIFFIN, and LARSEN, Circuit Judges.
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OPINION
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ALICE M. BATCHELDER, Circuit Judge. A corporate defendant in a civil lawsuit
moved to dismiss the plaintiff’s action based on a contractual forum-selection clause even
though the plaintiff was not a signatory to that contract. The district court applied the so-called
“closely related” doctrine, found that the plaintiff was sufficiently closely related to the contract
for the court to apply and enforce the forum-selection clause against that non-signatory plaintiff,
and dismissed the action. The plaintiff appeals, arguing that the district court applied the wrong
law, and correspondingly the wrong analytical approach, to determine the contract’s
applicability. Ultimately, we agree and for the reasons that follow, we REVERSE and
REMAND. |