Court Refuses Pastor’s Request to Void Forum-Selection Clause in Employment Contract
Chief Judge Lance Walker denied a pastor’s attempt to sidestep an Illinois forum-selection clause in his Abbott Labs. employment agreement.
Chief Judge Lance Walker ruled in Luzingu v. Abbott Labs., Inc. that the plaintiff, an Angolan-born Christian pastor hired as a production group leader in Maine, must honor the forum-selection clause in his employee agreement, which designates Illinois courts for any claims. The plaintiff argued that traveling to Illinois would impede his pastoral responsibilities and constitute undue hardship, citing his role leading three weekly services.
The court rejected this, noting the deposition will be taken in Maine and that a short trial in Illinois could be managed with telecommunications. It also observed that the employer routinely enforces the same clause in other cases, and Maine law does not provide a strong public policy exception for temporary religious inconvenience. Consequently, the plaintiff’s claim that litigation in Illinois would deprive him of his day in court was deemed insufficient. The decision underscores that contractual forum selections remain enforceable despite individual religious or immigration considerations.
Why it matters
It confirms that employment contracts can bind employees to out-of-state courts even when religious duties are cited.
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