The Wrex Group LLC v. USAT Logistics

CourtDistrict Court, E.D. Missouri
DecidedJune 28, 2024
Docket4:23-cv-00649
StatusUnknown

This text of The Wrex Group LLC v. USAT Logistics (The Wrex Group LLC v. USAT Logistics) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Wrex Group LLC v. USAT Logistics, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

THE WREX GROUP, LLC, d/b/a Chuck’s ) Wrecker Service, ) ) Plaintiff, ) ) v. ) Case No. 4:23CV649 HEA ) USAT LOGISTICS, a division of USA TRUCK, ) INC., JACKSON ELITE TRUCKING, LLC, and ) WALMART, INC., ) ) Defendant. )

OPINION, MEMORANDUM AND ORDER This matter is before the Court on Defendant Jackson Elite Trucking, LLC’s Motion to Dismiss and/or Motion to Transfer, [Doc. No. 45]. Defendant USA Truck, Inc. opposes the motion. Jackson has filed a Reply to this Response. The Court finds the matter ripe for consideration. Facts and Background1 Plaintiff’s Second Amended Complaint alleges the following: On January 19, 2020, Defendant USAT Logistics brokered a load of

1 The recitation of facts is set forth for the purposes of this motion only and in no way relieves the parties of the necessary proof of the facts herein. charcoal from a Royal Oak production facility in Salem, Missouri for transport to a Wal-Mart facility in Alabama, store 6006. USAT Logistics brokered or

subcontracted with Jackson Elite Trucking, LLC to transport the charcoal load. Even though the cargo was loaded on the Jackson Elite Trucking trailer, Jackson Elite Trucking was not the owner of the cargo. Royal Oak Enterprises has

advised Plaintiff that Walmart was the owner of the cargo claiming Walmart purchased it from Royal Oak prior to the incident. By brokering the charcoal load, Defendant USA Truck was acting as an agent for the charcoal’s owner and assumed responsibility for completing the cargo transportation, which did not

occur. On January 20, 2020, a Jackson Elite Trucking trailer was loaded at Royal Oak’s Salem, Missouri production facility. Even though USAT brokered the

load to Jackson Elite, pursuant to its contract with Walmart, it remained responsible for the delivery of the cargo and responsibility for all damages and losses related to the movement of the cargo. Shortly after transport began, an employee or agent of Jackson Elite lost

control of the tractor trailer on Highway 8 in Crawford County, Missouri resulting in significant damage/loss of the tractor and trailer. At the time of the collision the tractor trailer was being operated by an employee or agent of Jackson Elite in the

course and scope of employment for Jackson Elite. The Jackson Elite tractor and its trailer came to rest on their sides and completely blocked traffic. The Missouri State Highway Patrol contacted Plaintiff

and authorized Plaintiff to clear the wreckage so the highway could be reopened. In order to right the tractor it had to be separated from the trailer and a specialized tow vehicle called a “rotator” was used to hoist it back onto all four wheels.

In order to right the trailer, which had suffered significant structural damage, the contents of the trailer, 37,138 pounds of bagged charcoal, had to be manually transloaded onto a trailer Plaintiff rented for the purpose of clearing the wreckage. After the cargo was manually transloaded onto a waiting trailer, it was shrink

wrapped to protect it during transport. After the cargo was transloaded the “rotator” was again used to pick up the trailer, orient it and place it on a “dolly” for moving on public highways. The “dolly” was used because the structure of the trailer had

been compromised to the point that it could not be safely towed in an ordinary fashion. In order to remove the wreckage, Plaintiff had to employ additional laborers. Plaintiff had to pay for a “lane drop” which is a permit to temporarily close part of

the highway. Plaintiff offloaded the cargo inside its short-term storage facility in Rolla, Missouri which is in Phelps County. It alerted Jackson Elite Trucking, LLC and its insurer as to where the cargo was located, that it was in good and usable condition, and that a daily storage charge would be assessed.

Pursuant to its contract with Walmart, USA Truck was required to notify Walmart of any accidents which impaired the prompt delivery of the cargo in its possession or in the possession of any subcontractor. USAT Logistics was advised

by Plaintiff that the cargo it brokered is being warehoused but has made no effort to collect it or reimburse Plaintiff for the storage thereof or make arrangements to complete the transportation of the cargo to Walmart. To date, the approximately 37,000 pounds of Defendants’ bagged charcoal remains unclaimed in Plaintiff’s

storage facility. USA Truck filed a crossclaim against Jackson Elite for contractual indemnity and contribution for the alleged negligence of Jackson Elite’s driver.

Jackson Elite now moves to dismiss or to transfer pursuant to a forum selection clause contained in the Broker Provider Agreement entered into by USA Truck and Jackson Elite which provides: All controversies and claims arising hereunder shall be brought in the appropriate state or federal court having jurisdiction over Crawford County, Arkansas.

Legal Standard

The Eighth Circuit Court of Appeals appears to hold that a district court must apply federal law to the question of whether to enforce a forum selection clause. Union Elec. Co. v. Enery Ins. Mut. Ltd., 689 F.3d 968 (8th Cir. 2012). Forum selection clauses are prima facie valid and are enforced unless they are

unjust or unreasonable or invalid for reasons such as fraud or overreaching. M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1, 15 (1972). Atl. Marine Const. Co. v. U.S. Dist. Ct. for W. Dist. of Texas, 571 U.S. 49, 59 (2013) makes clear that “a

proper application of § 1404(a) requires that a forum-selection clause be ‘given controlling weight in all but the most exceptional cases.’” 571 U.S. at 59-60 quoting Stewart Org. v. Ricoh Corp., 487 U.S. 22, 33 (1988) (Kennedy, J., concurring)). They are enforceable unless they would actually deprive the

opposing party of his fair day in court. Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585, 590-95, 111 S.Ct. 1522, 113 L.Ed.2d 622 (1991). “In general, federal courts give considerable deference to a plaintiff's choice

of forum and thus the party seeking a transfer under section 1404(a) typically bears the burden of proving that a transfer is warranted.” Terra Int'l, Inc. v. Miss. Chem. Corp., 119 F.3d 688, 695 (8th Cir. 1997); see also K-V Pharm. Co. v. J. Uriach & CIA, S.A., 648 F.3d 588, 598 (8th Cir. 2011) (“The defendant has the burden of

persuasion in proving all elements necessary for the court to dismiss a claim based on forum non conveniens”). The Eighth Circuit has “declined to offer an ‘exhaustive list of specific factors to consider’ in making the transfer decision[.]”

In re Apple, Inc., 602 F.3d 909, 912 (8th Cir. 2010) (quoting Terra Int'l, 119 F.3d at 691). Instead, district courts considering a motion to transfer under § 1404(a) or for forum non conveniens “must evaluate both the convenience of the parties and

various public-interest considerations.” Atl. Marine, 571 U.S. at 62. Private factors include the “plaintiffs' choice of forum” and generally relate to the “practical problems that make trial of a case easy, expeditious and inexpensive.” Id. at 62,

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