RIDEWAY EXPRESS, INC. v. HAWKEYE TRANSPORTATION, LLC

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 9, 2025
Docket2:25-cv-02027
StatusUnknown

This text of RIDEWAY EXPRESS, INC. v. HAWKEYE TRANSPORTATION, LLC (RIDEWAY EXPRESS, INC. v. HAWKEYE TRANSPORTATION, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RIDEWAY EXPRESS, INC. v. HAWKEYE TRANSPORTATION, LLC, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

RIDEWAY EXPRESS, INC. : CIVIL ACTION : v. : NO. 25-2027 : HAWKEYE TRANSPORTATION : SERVICES, INC., HAWKEYE : TRANSPORT, LLC :

MEMORANDUM

MURPHY, J. October 9, 2025

You agree to perform a service for a company. The governing contract provides that a dispute arising out of the contract must be arbitrated. You perform the service, and your relationship with the company concludes. Two months later, the company complains about your performance on a forum visible to, and closely watched by, everyone in your industry. The complaint all but accuses you of breaching the contract and your reputation suffers materially. You decide to respond by suing for defamation and anything else your lawyer can think of. Do you have to take your claims to arbitration even though the challenged conduct came after the conclusion of the contract? For the contract and conduct at issue here, our answer is yes. In this case, Rideway Express, Inc., a motor carrier, entered into an agreement with Hawkeye Transportation Services, Inc. (HTS), a freight broker company, to deliver a shipment. The agreement said that a dispute arising out of the agreement must be arbitrated. It also expressly prohibited Rideway from re-brokering or co-brokering the shipment to another motor carrier — a deprecated practice. After Rideway delivered the shipment, HTS submitted a report on a portal visible to key industry stakeholders, accusing Rideway of double brokering. Rideway lost business and credibility. Rideway responded by coming here and suing HTS and Hawkeye Transport, LLC — an interstate motor carrier that shares a website with HTS and that, according to Rideway, operates jointly with HTS — for defamation per se, commercial disparagement, tortious interference, and false advertising. HTS seeks to enforce the arbitration provision, which it asserts governs this dispute, as well as an Iowa venue provision in the same agreement. Transport, for its part, seeks dismissal

for lack of personal jurisdiction or failure to state a claim. At oral argument, the parties clarified that no party seeks a stay and that enforcement of the arbitration provision should result in dismissal of the entire case. We now grant HTS’s motion to dismiss under Rule 12(b)(1) because Rideway’s claims must be arbitrated. All other bases for dismissal are denied. I. FACTUAL BACKGROUND

Rideway entered into a written Broker-Carrier Agreement (the Agreement) with HTS to deliver a shipment from Tenneessee to Florida on January 29, 2025. DI 1, Exhibit A, C. The Agreement contained this arbitration provision: “In the event of a dispute arising out of this Agreement, including but not limited to Federal or State statutory claims, the party’s sole recourse (except provided below) shall be to arbitration.” DI 1, Exhibit A at 31. The Agreement also included this forum provision: “(iii) (IF i AND/OR ii ARE ADOPTED, THEN iii MUST BE INCLUDED) Venue, controlling law, and jurisdiction in any legal proceedings under Subps. i or ii above shall be in the State of Iowa.” Id. The shipment was delivered on January 29th. However, nearly two months later, an individual submitted what is known as a FreightGuard report on two platforms — Carrier411 and MyCarrierPortal — that are used by brokers, shippers, and other stakeholders in the motor transport industry. DI 20, Exhibit A. A FreightGuard report is essentially a complaint about a party working in the motor transport industry. The contact information for the report’s author

2 listed “Hawkeye Transportation Services, Inc.” as the company and “919 2nd Ave SW, Spencer, IA 51301” as the address. Id. The principal place of business for HTS is 16 2nd Ave SW, Aberdeen, SD 57401, whereas 919 2nd Ave SW, Spencer, IA 51301 is the principal place of business for Transport — an interstate motor carrier that Rideway asserts operates jointly with

HTS. DI 20 at 2-3 (“HTS and Transport “jointly operate both as a motor carrier and as a freight broker business (‘Hawkeye Transportation’), sometimes transporting goods for third parties as a motor carrier, and other times arranging for the transportation of goods by third party motor carriers such as Rideway. Defendants promote themselves as a singular business operation with both freight brokering/logistics and drivers.”). The report stated, “BOOKED A LOAD WITH RIDEWAY 1/29. DRIVER CALLED ME TODAY SAYING THAT HE WAS SHORT PAYED ABOUT $1100 ON THIS LOAD FROM RIDEWAY. COME TO FIND OUT THAT THE CARRIER HAD HIS OWN MC WHEN HE HAULED THE LOAD AND RIDEWAY DOUBLE BROKED THE LOAD TO HIM.” DI 20, Exhibit A. The Agreement specifically stated that Rideway would not “re-broker, co-broker,

subcontract, assign, interline, or transfer the transportation of shipments hereunder to any other persons or entity conducting business under a different operating authority, without prior written consent of” HTS. DI 1, Exhibit A at 27. As explained by the parties during oral argument, re- brokering or co-brokering occurs when the carrier transfers its obligations to carry a shipment to another carrier and is a strongly disfavored practice in the transportation industry. When a FreightGuard report is submitted, the company about which the complaint is made receives a notification and 72 hours to respond to the report. DI 20, Exhibit A. Approximately one hour after receiving this notification, Rideway emailed HTS, asserting Rideway did not double broker

3 the shipment, providing various documentation in support of this assertion, and asking HTS to remove the report. Id., Exhibit C. Minutes later, HTS responded and stated the complainant was taking the report down. Id., Exhibit D. The report was still posted nine days later, prompting Rideway to follow up with HTS to request its removal. Id., Exhibit E. Approximately two

weeks after it was posted, the report was removed. Id. at 7. As a result of this report, Rideway initially brought a complaint against HTS and Hawkeye Transportation, LLC — which Rideway averred “jointly operate” and “promote themselves as a singular business operation” — for (1) defamation per se; (2) commercial disparagement; (3) tortious interference with business relations; (4) breach of contract; and (5) false advertising under the Lanham Act, 15 U.S.C. § 1125(a). DI 1 at 3, 10-22. As an exhibit, Rideway attached the Agreement. Id., Exhibit A. HTS filed a motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(1) and (6) based on the Agreement’s arbitration and venue provisions (DI 8), which Rideway opposed (DI 9). After it became apparent that Rideway intended to sue Hawkeye Transport, LLC instead of Hawkeye Transportation, LLC, Rideway amended its

complaint (DI 20), and we dismissed HTS’s motion to dismiss as moot (DI 19). Importantly, in Rideway’s amended complaint, Rideway removed the breach of contract claim, maintaining only the tort and the Lanham Act claims. DI 20. Rideway also did not attach the Agreement to its amended filing. According to Rideway, the FreightGuard report caused it to lose past and prospective business opportunities, suffer damages to its reputation and industry relationships, and experience a decline in carrier rankings and credibility among brokers. Id. at 7. It claims “multiple brokers refused to offer freight opportunities based expressly on the false FreightGuard report” and asserts there were no outstanding FreightGuard reports on Rideway

4 other than the report at issue. Id. at ¶ 15 (cleaned up). HTS and Transport filed separate motions to dismiss under Fed. R. Civ. P. 12

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Bluebook (online)
RIDEWAY EXPRESS, INC. v. HAWKEYE TRANSPORTATION, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rideway-express-inc-v-hawkeye-transportation-llc-paed-2025.