East Coast Karate Studios, Inc. v. Lifestyle Martial Arts, LLC
Florida District Court of Appeal
65 So. 3d 1127 (2011)
- Written by Liz Nakamura, JD
Facts
Jeffrey Wilson (defendant) signed a noncompete agreement during his employment with East Coast Karate Studios, Inc. (ECKS) (plaintiff), located in Broward County, Florida. The noncompete agreement included a mandatory forum-selection clause favoring Broward County and barred Wilson from working for a martial arts business within 25 miles of Broward County for two years following the termination of Wilson’s employment with ECKS. Wilson resigned, moved to Palm Beach County, and was immediately employed by Lifestyle Martial Arts, LLC (LMA), a Palm Beach County martial arts studio located less than 25 miles away from Broward County. Wilson and LMA filed an action in Palm Beach County seeking a declaratory judgment that the noncompete agreement was unenforceable. ECKS moved to transfer the declaratory-judgment action to Broward County pursuant to the noncompete agreement’s mandatory forum-selection clause. Wilson and LMA countered, arguing that the forum-selection clause was unenforceable against LMA because LMA was not a signatory to the noncompete agreement. The circuit court in Palm Beach County refused to transfer the declaratory-judgment action to Broward County. Subsequently, ECKS filed an action in Broward County (1) against Wilson for breach of the noncompete agreement; and (2) against LMA for tortious-interference with the noncompete agreement (the breach-and-tortious-interference action). Wilson and LMA moved to transfer the breach-and-tortious-interference action to Palm Beach County. The circuit court in Broward County granted Wilson and LMA’s motion to transfer the breach-and-tortious-interference action to Palm Beach County. ECKS appealed both circuit courts’ transfer rulings, arguing that the mandatory forum-selection clause was enforceable against LMA even though LMA was a non-signatory.
Rule of Law
Issue
Holding and Reasoning (Gerber, J.)
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