Narrow Path Transport LLC v. Total Quality Logistics, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedFebruary 9, 2026
DocketA-2856-24
StatusUnpublished

This text of Narrow Path Transport LLC v. Total Quality Logistics, LLC (Narrow Path Transport LLC v. Total Quality Logistics, LLC) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Narrow Path Transport LLC v. Total Quality Logistics, LLC, (N.J. Ct. App. 2026).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited . R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-2856-24

NARROW PATH TRANSPORT LLC,

Plaintiff-Respondent,

v.

TOTAL QUALITY LOGISTICS, LLC,

Defendant-Appellant. __________________________

Submitted January 14, 2026 – Decided February 9, 2026

Before Judges Paganelli and Vanek.

On appeal from the Superior Court of New Jersey, Law Division, Burlington County, Docket No. SC-000213- 25.

Kublanovsky Law LLC, attorneys for appellant (Eugene Kublanovsky and Erik Dykema, on the brief).

Respondent has not filed a brief.

PER CURIAM Defendant Total Quality Logistics, LLC (TQL) appeals from a judgment

entered for plaintiff Narrow Path Transport, LLC (Narrow Path) in the Special

Civil Part, Small Claims Division, after the trial court denied TQL's motion to

dismiss the complaint based on a contractual forum selection clause requiring

the parties to litigate in Ohio.1 We vacate the judgment and remand for the court

to set forth a statement of reasons comporting with Rule 1:7-4 after determining

whether the forum selection clause is enforceable or has been waived, based on

prevailing law. In the event the court finds litigation was properly commenced

in New Jersey, it shall conduct a new trial based on sworn testimony.

I.

TQL is an Ohio-based company that arranges freight transportation

services on behalf of third-party customers. Narrow Path is a New Jersey-based

freight carrier.

On or about July 17, 2023, TQL entered into a "Broker-Carrier"

Agreement (the Agreement) with Narrow Path to transport vehicle trailers for

TQL's customers on request. The Agreement contained a provision requiring

Narrow Path to indemnify TQL against certain claims related to its performance

under the Agreement. The Agreement allowed TQL to offset Narrow Path's

1 The record does not reference a separate order denying TQL's motion. A-2856-24 2 indemnity obligations to TQL or its customers against any amount due to

Narrow Path.

Section 15 of the Agreement provides:

This Agreement will be governed by the laws of the State of Ohio, except to the extent that federal transportation Laws preempt those laws, without giving effect to conflict of law provisions which would result in the application of any law other than Ohio law. The [p]arties consent to the jurisdiction of the state court located in Clermont County, Ohio, waive any objection to the jurisdiction of that court, and agree that any dispute between the [p]arties, including, without limitation, those arising under or related to this Agreement, will be brought in that court, which will have exclusive jurisdiction over such dispute.

Narrow Path subsequently filed a small claims complaint against TQL

seeking reimbursement of an amount TQL had deducted from Narrow Path's

earnings on other TQL jobs to pay for a customer's damages pursuant to the

Agreement's indemnification and offset provisions. The court scheduled trial

for April 24, 2025. A few days before trial, TQL moved to dismiss the complaint

based on the Agreement's forum selection clause, which requires litigation to

proceed in an Ohio state court.

Initially only Narrow Path's representatives were present in the courtroom

for trial; TQL's representative later joined remotely. The record does not reflect

any of the individuals were sworn in before providing trial testimony. Narrow

A-2856-24 3 Path did not argue the forum selection clause was inapplicable in opposition to

TQL's motion. After hearing from Narrow Path as to its request for the entry of

judgment, the judge denied TQL's dismissal motion, stating that TQL subjected

itself to the jurisdiction of New Jersey courts based on the parties' course of

conduct, which included seventy prior transports.

The judge then entered a monetary judgment in favor of Narrow Path

based on unsworn trial proofs. TQL argues on appeal that the judge erred by

denying its dismissal motion seeking to enforce the Agreement's forum selection

clause and by entering a judgment absent subject matter jurisdiction.

II.

A court cannot hear a case if it lacks subject matter jurisdiction. Peper v.

Princeton Univ. Bd. of Trustees, 77 N.J. 55, 65 (1978). "A court lacks subject

matter jurisdiction over a case if it is brought in an ineligible forum. . . . [Thus]

a plaintiff cannot file suit in a court if he or she has entered into an enforceable

agreement to bring such claims in another forum." Hoffman v. Supplements

Togo Mgmt., LLC, 419 N.J. Super. 596, 606 (App. Div. 2011).

Our standard of review of a trial court's determination as to whether it has

subject matter jurisdiction is well settled. We review whether a court has subject

matter jurisdiction de novo. AmeriCare Emergency Med. Serv., Inc. v. City of

A-2856-24 4 Orange Twp., 463 N.J. Super. 562, 570 (App. Div. 2020). Likewise, our review

of a court's ruling on the enforceability of a forum selection clause is de novo.

Largoza v. FKM Real Estate Holdings, Inc., 474 N.J. Super. 61, 72 (App. Div.

2022).

Our ability to resolve an appeal is largely dependent on the trial court's

compliance with its Rule 1:7-4 obligation to "'state clearly [its] factual findings

and correlate them with relevant legal conclusions, so that parties and the

appellate courts [are] informed of the rationale underlying th[ose]

conclusion[s].'" Avelino-Catabran v. Catabran, 445 N.J. Super. 574, 594-95

(App. Div. 2016) (alterations in original). Without a statement of reasons, "we

are left to conjecture as to what the judge may have had in mind." Salch v.

Salch, 240 N.J. Super. 441, 443 (App. Div. 1990).

III.

Based on our review of the record and prevailing law, we are constrained

to vacate the judgment and remand for the court to comply with Rule 1:7-4 as

to its denial of TQL's dismissal motion because the determination not to enforce

the forum selection clause was without explanation.

A.

It is well established that contracting parties may agree to resolve any

A-2856-24 5 dispute arising from their agreement in a particular forum. See McNeill v. Zoref,

297 N.J. Super. 213, 219 (App. Div. 1997). "[F]orum selection clauses are prima

facie valid and enforceable in New Jersey." Largoza, 474 N.J. Super. at 72

(alteration in original) (quoting Caspi v. Microsoft Network, LLC, 323 N.J.

Super. 118, 122 (App. Div. 1999)). "Forum selection clauses 'will be enforced

unless the party objecting thereto demonstrates: (1) the clause is a result of fraud

or overweening bargaining power, or (2) the enforcement in a foreign forum

would violate strong public policy of the local forum, or (3) enforcement would

be seriously inconvenient for the trial.'" Id. at 72-73 (quoting McNeill, 297 N.J.

at 219).

Where an enforceable forum selection clause binds the parties, whether

New Jersey courts could have exercised personal jurisdiction over the defendant

is irrelevant. See Allure Pet Products, LLC v. Donnelly Mktg. & Dev. LLC, 477

N.J. Super. 541, 555 (App. Div.

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800 A.2d 132 (New Jersey Superior Court App Division, 2002)
Salch v. Salch
573 A.2d 520 (New Jersey Superior Court App Division, 1990)
Peper v. Princeton University Board of Trustees
389 A.2d 465 (Supreme Court of New Jersey, 1978)
Knorr v. Smeal
836 A.2d 794 (Supreme Court of New Jersey, 2003)
Caspi v. Microsoft Network, LLC
732 A.2d 528 (New Jersey Superior Court App Division, 1999)
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Narrow Path Transport LLC v. Total Quality Logistics, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/narrow-path-transport-llc-v-total-quality-logistics-llc-njsuperctappdiv-2026.