Murphy v. Schneider Nat’l, Inc., 349 F.3d 1224 (9th Cir. 2003)

Charles E. Murphy was injured on premises owned by Trane Company while he was working as a long-haul trucker for Schneider National, Inc. Murphy filed a personal injury action against Schneider (which had failed to maintain a workers’ compensation policy) and Trane in the United States District Court for the District of Oregon based on diversity of citizenship. Invoking a forum-selection clause that was contained in the 31-page employment contract between Schneider and Murphy, Schneider moved to dismiss the action based on improper venue; Trane moved to dismiss the action based on the doctrine of forum non conveniens. In opposition to Schneider’s motion, Murphy presented evidence that because of his financial and physical limitations, enforcement of the forum-selection clause would deprive him of his day in court. The district court granted both defendants’ motions. The Ninth Circuit vacated the judgment in part, holding that the district court had abused its discretion by failing to accept the non-moving party’s (Murphy’s) allegations as true and failing to resolve all disputed facts in his favor. The Court further held that the district court should, if in its discretion it deemed it necessary, conduct an evidentiary hearing to determine the facts in dispute.