Michigan
How Atlantic Marine Construction Co., Inc. v. U.S. District Court for the Western District of Texas applies in Michigan: state-specific rules, key cases, and bar exam notes for Civil Procedure.
Michigan law generally aligns with federal standards regarding forum selection clauses, emphasizing the need for enforcement unless extraordinary circumstances exist. Specifically, Michigan courts assess whether the chosen forum would be unreasonable or unjust.
Under Michigan law, a forum selection clause is enforceable unless the opposing party can demonstrate that enforcement would be unreasonable, unjust, or that the clause was procured through misrepresentation or overreaching.
Affirmed the enforceability of forum selection clauses, emphasizing the importance of jurisdictional fairness.
Held that a forum selection clause is valid unless shown to be unreasonable or against public policy.
Reinforced that Michigan courts will uphold forum selection clauses unless the party challenging them meets a rigorous burden of proof.
Michigan's approach mirrors the federal standard articulated in Atlantic Marine, reinforcing the need for enforcement of forum selection clauses while allowing for exceptions. Both systems require that the challenging party meet a high burden to invalidate such clauses.
Issues related to forum selection clauses may appear on the Michigan bar exam, particularly in context of civil procedure, emphasizing the importance of understanding enforceability standards.