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Melia v. Zenhire, Inc.

967 N.E.2d 580 (2012)

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Melia v. Zenhire, Inc.

Massachusetts Supreme Judicial Court
967 N.E.2d 580 (2012)

Facts

Massachusetts-based Edward Melia (plaintiff) entered into an employment contract with New York-based Zenhire, Inc. (defendant). The contract’s forum-selection clause provided that any dispute arising from Melia’s employment was to be litigated in New York. The contract’s choice-of-law clause provided that New York law would govern. Melia spent time in New York early in his Zenhire employment, but Melia, whose job involved business development, met with prospective customers only in Massachusetts. Melia sued Zenhire in Massachusetts when Zenhire stopped paying Melia, asserting claims under, among other things, the Massachusetts Wage Act (MWA). Zenhire moved to dismiss the complaint based on the forum-selection clause. Melia responded that the clause was unenforceable at least with respect to the MWA claim because (1) Massachusetts public policy required a Massachusetts forum for MWA claims and (2) a New York court utilizing New York’s choice-of-law rules might apply New York’s less employee-protective wage statute instead of the MWA. The superior court ruled that the forum-selection clause was valid because there was no evidence of fraud or other impropriety and that a New York court might apply the MWA. Melia appealed.

Rule of Law

Issue

Holding and Reasoning (Cordy, J.)

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Conflict of Laws

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