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Satterwhite Aviation Service v. International Profit Associates, Inc.
Citation: Not availableDocket: 01-07-00053-CV
Court: Court of Appeals of Texas; January 30, 2008; Texas; State Appellate Court
Original Court Document: View Document
On January 31, 2008, the Texas Court of Appeals affirmed the trial court's dismissal of Satterwhite Aviation Services, Inc.'s lawsuit against International Profit Associates, Inc. (IPA), which was based on claims including violations of the Texas Deceptive Trade Practices Act, common law fraud, and negligent misrepresentation. IPA successfully argued for dismissal, citing a mandatory venue provision in their agreement that designated Lake County, Illinois as the exclusive jurisdiction for disputes. The court analyzed the arbitration and forum selection clause from the June 2006 agreement, which allowed Satterwhite to choose between arbitration or litigation for disputes arising from the agreement. However, it specified that, for "all other matters," exclusive jurisdiction and venue would be in Lake County, Illinois, applying Illinois law. Satterwhite contended that the clause did not mandate a specific jurisdiction for its claims, interpreting it as allowing litigation in any appropriate venue. The court found that the language of the clause was not ambiguous and required all claims against IPA to be litigated in Lake County. Consequently, the court upheld the trial court's decision, confirming that forum selection clauses are enforceable in Texas if the parties have consented to a specific jurisdiction and the other state recognizes such provisions. In Greenwood v. Tillamook Country Smoker, Inc., the court addressed Satterwhite's argument regarding its choice to litigate rather than arbitrate. Satterwhite contended that without a mandatory venue requirement, it could sue in any appropriate court. The court emphasized that the primary objective in contract interpretation is to ascertain the parties' intentions as articulated in the contract itself, rather than their current interpretations. It asserted that the agreement must be enforced as written, regardless of the wisdom of the contracting decisions. The phrase "with regard to all other matters" pertains to issues not subject to binding arbitration. The interpretation of the forum selection clause, when considered alongside the arbitration clause, indicates that Satterwhite had two options: to either submit the dispute to binding arbitration or file a lawsuit specifically in Lake County, Illinois. Consequently, the court concluded that Satterwhite was obligated to bring the suit in Lake County unless it chose arbitration. The trial court's decision to grant the motion to dismiss was upheld, affirming the judgment. The ruling was supported by Justices Nuchia, Hanks, and Higley.