Gehl v. Gleason

U.S. District Court, District of Minnesota

Gehl v. Gleason

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Larry Gehl,                             Civil No. 23-2244 (DWF/JFD)      

               Plaintiff,                                                

v.                                               MEMORANDUM              
                                            OPINION AND ORDER            
James P. Gleason,                                                        

               Defendant.                                                


                        INTRODUCTION                                     
    This matter is before the Court on Defendant James Gleason’s motion to dismiss 
for forum non conveniens or, in the alternative, to stay the proceedings.  (Doc. No. 18.)  
Plaintiff Larry Gehl opposes the motion.  (Doc. No. 27.)  For the reasons set forth below, 
the Court denies the motion.                                              
                         BACKGROUND                                      
    A.   Current Action                                                  
    Gehl loaned $2,120,200.00 to a company called Xtraction (the “Loan”).  (Doc. 
No. 1 (“Compl.”) ¶ 7.)  Xtraction then executed a Promissory Note evidencing the Loan.  
(Id.)  The Note was “secured by the personal guarantees and pledge agreements of 
Robert M. Gurnee and James P. Gleason.”  (Id. ¶ 8.)  Gleason executed a Personal 
Guarantee (“Guarantee”) in January 2021, guaranteeing the timely and complete payment 
by Xtraction on the Loan.  (Id. ¶ 9.)  Gleason’s liability under the Guarantee is 17.5% “of 
the outstanding balance of the principal under the Note at the time [Gehl] seeks to 
enforce the guarantee.”  (Id. ¶ 10.)  Gleason also executed a Pledge Agreement, pledging 
his 17.5% ownership interest in Xtraction as security.  (Id. ¶¶ 11-12.)   
    Gehl now alleges that Xtraction has failed to make all required monthly payments.  

(Id. ¶ 15.)  The Note is in default, and Gehl alleges that Gleason is personally liable for 
the default.  (Id. ¶¶ 16-19.)  Gehl alleges that Gleason owes $449,950.15, which is 17.5% 
of the principal plus interest.  (Id. ¶ 21.)                              
    B.   California Action                                               
    In a separate California action, Gleason has sued Xtraction, Gehl, and 27 other 

defendants.  (Doc. No. 22-1 (“CA Compl.”).)  Gleason brings several claims related to 
his work for Xtraction.                                                   
    Gleason and Robert Gurnee started Xtraction together.  (Id. ¶¶ 1-3.)  Xtraction is a 
mattress recycling company.  (Id.)  Gleason alleges that he and Gurnee “agreed to co-own 
this business, to share in its profits, and to create new sites across the United States as 

more and more states implemented mattress recycling requirements.”  (Id. ¶ 2.)  Gleason 
and Gurnee brought Gehl in as an investor in the company.  (Id. ¶ 25.)  Xtraction issued a 
total of 10,000 shares, and Gleason held 1,950 of them.  (Id.)            
    Gleason, Gurnee, and Gehl were the three initial members of Xtraction’s Board of 
Directors.  (Id. ¶ 27.)  Gleason entered into an Employment and Stock Repurchase 

Agreement where he agreed to work as Xtraction’s Chief Operating Officer.  (Id. ¶¶ 28-
29.)  Gleason was paid a base salary and was also entitled to receive “Other 
Compensation,” in the event that Xtraction opened a new site, which consisted of “30% 
of net operating income for any month in which Xtraction generated net operating 
income of at least $25,000.”  (Id. ¶ 30.)  Gleason alleges that Gehl and Gurnee 
represented to him, through the Employment Agreement, that “if [Gleason] poured his 
time and efforts into expanding Xtraction, he would receive increased compensation.”  

(Id. ¶ 31.)  Gleason alleges that at the time Gehl and Gurnee made these representations 
they had already made plans to “eliminate Mr. Gleason’s interests and to establish a 
competing business to Xtraction without Mr. Gleason’s involvement.”  (Id. ¶ 32.)  
Gleason also personally loaned Xtraction $31,000, which has not been paid back.  (Id. 
¶¶ 34, 115-20.)                                                           

    In 2020, Gurnee led negotiations to purchase another mattress recycling company, 
Rest in Peace Recycling, that operated in central California.  (Id. ¶ 39.)  Gehl provided 
financing for the purchase.  (Id. ¶ 40.)  As a condition of the funding, Gehl required 
Gleason to sign a Second Amended and Restated Bylaws.  (Id.)  The new bylaws 
provided, in part, that if a shareholder ceased being a director, then Xtraction was 

required to purchase the shareholder’s shares.  (Id.)  The new bylaws also expanded the 
Board of Directors from three to four.  (Id. ¶¶ 41-42.)  Gleason alleges that “[o]nce 
again,” Gurnee and Gehl represented to Gleason that “he would be rewarded for his time 
and efforts in expanding Xtraction and increasing its profits.”  (Id. ¶ 43.)  
    Gurnee and Gleason made efforts to expand Xtraction to other states.  (Id. ¶ 38.)  

Gleason alleges that he and Gurnee “regularly discussed strategy for an East Coast 
expansion.”  (Id. ¶ 77.)  Gehl and Gurnee discussed with Gleason “potentially forming a 
new limited liability company for Xtraction’s expansion to the East Coast.”  (Id. ¶ 82.)  In 
August 2020, Gurnee indicated that he would be dedicating most of his time to 
“expansion and growth.”  (Id. ¶ 86.)  Gleason alleges that Gurnee and Gehl feigned 
interest in expanding Xtraction “to take advantage of Mr. Gleason’s extensive business 
and engineering experience” and in furtherance of their “secret plans to start a competing 

business to Xtraction.”  (Id. ¶¶ 89-90.)                                  
    In July 2021, Gleason’s employment was terminated.  (Id. ¶ 47.)  Following his 
termination, Gleason discovered that Gurnee and Gehl started a new mattress recycling 
company.  (Id. ¶ 54.)  The new company, Gehl, Gurnee, & Young (“GGY”), was 
registered with the Minnesota Secretary of State in August 2021.  (Id. ¶ 55.)  GGY 

currently does business in Rhode Island and Connecticut.  (Id.)  Gleason alleges that 
Gurnee and Gehl “used Xtraction’s property, contacts, business model, and goodwill to 
create a competing business for themselves that was solely created to cut out Mr. 
Gleason.”  (Id. ¶ 57.)  Gleason also has not been compensated for his shares in Xtraction.  
(Id. ¶ 51.)                                                               

    Gleason asserts numerous claims against the defendants, including breach of 
partnership agreement, breach of fiduciary duty, fraud, intentional interference with 
contractual relations, intentional interference with prospective economic advantage, 
breach of contract, restitution, violation of Labor Code § 2802, and violation of 
California Business Professions Code §17200.1                             




1    In November 2023, the California court granted Gleason leave to amend his 
§ 17200 claim, but Gleason indicated that he intends to dismiss the claim.  (Doc. No. 20 
at 7.)                                                                    
    C.   Procedural Posture                                              
    Gleason moves to dismiss this case, involving the Loan, for forum non conveniens, 
or, in the alternative, to stay the proceedings.  Gleason asserts that this case significantly 

overlaps with the California action.  Gehl acknowledges in his Complaint that Gleason’s 
ownership interest in Xtraction “is currently being litigated in California” (Compl. ¶ 41), 
but he asserts that this action is distinct from the California action.  Moreover, Gehl 
asserts that Gleason is bound by a forum-selection clause.                
                          DISCUSSION                                     

    Gleason moves to dismiss this case based on the doctrine of forum non 
conveniens.  “‘The principle of forum non conveniens permits a court to decline 
jurisdiction even though venue and jurisdiction are proper’ because the action should 
instead be tried in another judicial forum.”  United Fire & Cas. Co. v. Weber, Inc., 
434 F. Supp. 3d 729
, 733 (D. Minn. 2020) (quoting Mizokami Bros. of Ariz. v. Mobay Chem. 

Corp., 
660 F.2d 712, 717
 (8th Cir. 1981)).                                
    The Court considers a number of factors under the doctrine of forum non 
conveniens, including private and public interest factors.  Private-interest factors “include 
relative ease of access to sources of proof, the cost of obtaining attendance of willing 
witnesses, and other practical issues that can make litigation of a case more feasible.”  
Id.
  

Public-interest factors include “the administrative difficulties flowing from court 
congestion; the local interest in having localized controversies decided at home; and the 
interest in having the trial of a diversity case in a forum that is at home with the law.”  
Id.
 
(quoting Atl. Marine Const. Co. v. U.S. Dist. Ct. for W. Dist. of Tex., 
571 U.S. 49
, 62 n.6 
(2013)).  The party seeking transfer bears the burden of proof to show that the balance of 
factors “strongly” favors the movant.  United Mortg. Corp. v. Plaza Mortg. Corp., 
853 F. Supp. 311, 315
 (D. Minn. 1994).                                           

    A valid forum-selection clause, however, changes the forum non conveniens 
analysis.  “A valid forum-selection clause should be given controlling weight in all but 
the most exceptional cases.”  Enerplus Res. (USA) Corp. v. Wilkinson, 
865 F.3d 1094
, 
1097 n.5 (8th Cir. 2017) (internal quotations and citation omitted).  A forum-selection 
clause “may be set aside if it is unjust, unreasonable, or invalid due to fraud or 

overreaching.”  Wells Fargo Fin. Leasing, Inc. v. Orlando Magic, Ltd., 
431 F. Supp. 2d 955, 961
 (S.D. Iowa 2006).  When there is a valid forum-selection clause, “the court must 
disregard consideration of private factors” when applying the forum non conveniens 
doctrine.  United Fire & Cas. Co., 434 F. Supp. 3d at 733.                
I.   Forum-Selection Clause                                               

    All the loan documents—the Promissory Note, Guarantee, and Pledge—contain 
forum-selection clauses.  Gleason breezes over the forum-selection clauses in his initial 
briefing.  And for the first time in his reply brief, Gleason alleges that the forum-selection 
clauses are invalid because they are the product of fraud.  “The party resisting 
enforcement of a valid forum selection clause bears a heavy burden in convincing the 

Court that it should not be held to its bargain.”  Zamora Ent., Inc. v. William Morris 
Endeavor Ents., L.L.C., 
667 F. Supp. 2d 1032, 1039
 (S.D. Iowa 2009).  Forum-selection 
clauses are prima facie valid and will be given effect unless the party opposing the clause 
makes a “strong showing that it should be set aside.”  Carnival Cruise Lines, Inc. v. 
Shute, 
499 U.S. 585, 591
 (1991) (internal quotations and citation omitted). 
    “[A] forum-selection clause in a contract is not enforceable if the inclusion of that 

clause in the contract was the product of fraud or coercion.”  Marano Enters. of Kan. v. 
Z-Teca Rests., L.P., 
254 F.3d 753
, 757 (8th Cir. 2001) (internal quotations and citation 
omitted) (emphasis in original).  In the California action, Gleason alleges that over 
twenty defendants, including Gehl, fraudulently induced him to invest time and effort 
into Xtraction and undercut Xtraction’s business endeavors by secretly forming a new 

company in direct competition with Xtraction.  (CA Compl. ¶¶ 89-93.)      
    Gleason asserts that the loan documents, including the Guaranty and Pledge, were 
executed, in part, based on Gehl and the other defendants’ false assertions that they 
planned to “develop Xtraction, including expanding operations outside California.”  
(Doc. No. 29 at 4.)  The complaint in the California action, however, does not explain the 

purpose of the Loan or the facts surrounding Gleason’s decision to sign the Guaranty and 
Pledge.  In fact, the complaint does not mention the Guaranty or Pledge at all.  The 
complaint does allude to certain funding provided by Gehl to finance the purchase of a 
separate California mattress recycling and disposal company in late 2020—around the 
same time the Loan was executed.  (See CA Compl. ¶¶ 39-40.)  If this is the same loan at 

issue here, then these facts seem to contradict Gleason’s assertion that the defendants’ 
stated intention to expand Xtraction was false, as it appears that the purchase of the other 
California mattress recycling company was successful.  (CA Compl. ¶ 45.)   
    Nonetheless, it is not clear to the Court whether the financing by Gehl referenced 
in the California complaint is related to the Loan at issue in this case.2  Other than a 
conclusory assertion that this Loan was “necessarily” the “product of fraud” (Doc. No. 29 

at 4), Gleason offers no specifics about the Loan, how Gleason was induced by fraud to 
sign the Guaranty and Pledge, or how the fraud specifically relates to the forum-selection 
clauses.  See Marano, 254 F.3d at 757 (noting that the complaint “d[id] not even remotely 
suggest that the [forum-selection] clauses were inserted into the agreements as the result 
of fraud”).  Gleason’s general assertion that he “was induced by fraud” to sign the 

Guaranty and Pledge “is insufficient to raise an issue that the forum-selection clauses 
within those agreements may be unenforceable because of fraud.”  Id.; see also Elliott v. 
Manhattan Cryobank, Inc., No. 19-cv-190, 
2019 WL 1318565
, at *2 (E.D. Mo. Mar. 22, 
2019) (“[G]eneral allegations of fraud in the inducement are insufficient to raise an issue 
that the forum-selection clause may be unenforceable because of fraud.”). 

    A forum-selection clause may also be set aside if enforcement of the clause would 
mean that a party would “for all practical purposes be deprived of his day in court.”  M/S 
Bremen v. Zapata Off-Shore Co., 
407 U.S. 1, 18
 (1972).  Here, neither party argues that 
they would be deprived of their day in court if required to litigate this action here.  The 
Court therefore concludes that the forum-selection clause is valid.       




2    Gehl acknowledged at the hearing that the Loan was indeed executed to purchase 
the California mattress company referenced in the California complaint; however, neither 
party mentioned this in the pleadings, briefings, or declarations.        
II.  Public-Interest Factors                                              
    Because the forum-selection clause is valid, the Court must “disregard 
consideration of private factors” when applying the forum non conveniens doctrine.  

United Fire & Cas. Co., 434 F. Supp. 3d at 733; see also Atl. Marine Const. Co., 
571 U.S. at 64
 (holding that a court must “deem the private-interest factors to weigh entirely 
in favor of the preselected forum” when there is a valid forum-selection clause).  Public-
interest factors will rarely overcome a forum-selection clause, and the forum-selection 
clause should be enforced in all but “unusual cases.”  Atl. Marine Const. Co., 
571 U.S. at 64
.                                                                    
    Gleason argues that the public-interest factors support dismissal because “all of 
the facts relevant to this proceeding . . . are all the subject matter of the California 
Action.”  (Doc. No. 29 at 5.)  As the Court noted above, facts surrounding the Loan 
specifically are not being litigated in the California action, and the California complaint 

does not even mention the Pledge or Guaranty.  Gleason further argues that he lives in 
California and the facts underlying Gehl’s claims arose in California.  But this showing is 
not enough to demonstrate that the public interest factors overwhelmingly support 
dismissal.  Moreover, as Gehl asserts, Minnesota law will govern this action, and this 
Court is in a better position to apply Minnesota law.  Overall, Gleason has not met his 

heavy burden of demonstrating that this is an unusual case that warrants dismissal despite 
a valid forum-selection clause.                                           
III.  Stay                                                                
    Lastly, Gleason argues that the Court should stay this action pending resolution of 
the California action.  The Colorado River abstention doctrine “permits federal courts to 

decline to exercise jurisdiction over cases where ‘parallel’ state court litigation is 
pending, meaning that there is ‘a substantial likelihood that the state proceeding will fully 
dispose of the claims presented in the federal court.’”  Spectra Commc’ns Grp., L.L.C. v. 
City of Cameron, 
806 F.3d 1113, 1121
 (8th Cir. 2015) (quoting Cottrell v. Duke, 
737 F.3d 1238, 1245
 (8th Cir. 2013)).  The Court is doubtful that the California action will 

dispose of any of the issues in this case, as the California action does not involve 
litigation related to liability under the Loan.3  Colorado River abstention is only 
applicable “where the surrender of federal jurisdiction is supported by the clearest of 
justification.”  
Id.
 (internal quotations and citation omitted).  Gleason has not provided a 
sufficient basis to support a stay under Colorado River.  To the extent necessary, 

however, the Court will work with the California state court to coordinate discovery and 
otherwise streamline the proceedings, if possible.                        
                         CONCLUSION                                      
    For the reasons outlined above, the Court denies Gleason’s motion to dismiss.  



3    The California action does involve litigation regarding Gleason’s ownership of his 
shares of Xtraction.  These are the same shares that Gleason pledged in the Pledge 
Agreement.  But Gleason’s liability under the Loan and Gehl’s right to Gleason’s shares, 
should Gleason be deemed the owner, are separate issues and will not be addressed in the 
California action.                                                        

ORDER

    Based upon the foregoing, and the files, records, and proceedings herein, IT IS 
HEREBY ORDERED that Defendant James Gleason’s motion to dismiss for forum non 

conveniens, or, in the alternative, to stay proceedings (Doc. No. [18]) is respectfully 
DENIED.                                                                   

Dated:  April 9, 2024         s/Donovan W. Frank                          
                             DONOVAN W. FRANK                            
                             United States District Judge                

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Larry Gehl,                             Civil No. 23-2244 (DWF/JFD)      

               Plaintiff,                                                

v.                                               MEMORANDUM              
                                            OPINION AND ORDER            
James P. Gleason,                                                        

               Defendant.                                                


                        INTRODUCTION                                     
    This matter is before the Court on Defendant James Gleason’s motion to dismiss 
for forum non conveniens or, in the alternative, to stay the proceedings.  (Doc. No. 18.)  
Plaintiff Larry Gehl opposes the motion.  (Doc. No. 27.)  For the reasons set forth below, 
the Court denies the motion.                                              
                         BACKGROUND                                      
    A.   Current Action                                                  
    Gehl loaned $2,120,200.00 to a company called Xtraction (the “Loan”).  (Doc. 
No. 1 (“Compl.”) ¶ 7.)  Xtraction then executed a Promissory Note evidencing the Loan.  
(Id.)  The Note was “secured by the personal guarantees and pledge agreements of 
Robert M. Gurnee and James P. Gleason.”  (Id. ¶ 8.)  Gleason executed a Personal 
Guarantee (“Guarantee”) in January 2021, guaranteeing the timely and complete payment 
by Xtraction on the Loan.  (Id. ¶ 9.)  Gleason’s liability under the Guarantee is 17.5% “of 
the outstanding balance of the principal under the Note at the time [Gehl] seeks to 
enforce the guarantee.”  (Id. ¶ 10.)  Gleason also executed a Pledge Agreement, pledging 
his 17.5% ownership interest in Xtraction as security.  (Id. ¶¶ 11-12.)   
    Gehl now alleges that Xtraction has failed to make all required monthly payments.  

(Id. ¶ 15.)  The Note is in default, and Gehl alleges that Gleason is personally liable for 
the default.  (Id. ¶¶ 16-19.)  Gehl alleges that Gleason owes $449,950.15, which is 17.5% 
of the principal plus interest.  (Id. ¶ 21.)                              
    B.   California Action                                               
    In a separate California action, Gleason has sued Xtraction, Gehl, and 27 other 

defendants.  (Doc. No. 22-1 (“CA Compl.”).)  Gleason brings several claims related to 
his work for Xtraction.                                                   
    Gleason and Robert Gurnee started Xtraction together.  (Id. ¶¶ 1-3.)  Xtraction is a 
mattress recycling company.  (Id.)  Gleason alleges that he and Gurnee “agreed to co-own 
this business, to share in its profits, and to create new sites across the United States as 

more and more states implemented mattress recycling requirements.”  (Id. ¶ 2.)  Gleason 
and Gurnee brought Gehl in as an investor in the company.  (Id. ¶ 25.)  Xtraction issued a 
total of 10,000 shares, and Gleason held 1,950 of them.  (Id.)            
    Gleason, Gurnee, and Gehl were the three initial members of Xtraction’s Board of 
Directors.  (Id. ¶ 27.)  Gleason entered into an Employment and Stock Repurchase 

Agreement where he agreed to work as Xtraction’s Chief Operating Officer.  (Id. ¶¶ 28-
29.)  Gleason was paid a base salary and was also entitled to receive “Other 
Compensation,” in the event that Xtraction opened a new site, which consisted of “30% 
of net operating income for any month in which Xtraction generated net operating 
income of at least $25,000.”  (Id. ¶ 30.)  Gleason alleges that Gehl and Gurnee 
represented to him, through the Employment Agreement, that “if [Gleason] poured his 
time and efforts into expanding Xtraction, he would receive increased compensation.”  

(Id. ¶ 31.)  Gleason alleges that at the time Gehl and Gurnee made these representations 
they had already made plans to “eliminate Mr. Gleason’s interests and to establish a 
competing business to Xtraction without Mr. Gleason’s involvement.”  (Id. ¶ 32.)  
Gleason also personally loaned Xtraction $31,000, which has not been paid back.  (Id. 
¶¶ 34, 115-20.)                                                           

    In 2020, Gurnee led negotiations to purchase another mattress recycling company, 
Rest in Peace Recycling, that operated in central California.  (Id. ¶ 39.)  Gehl provided 
financing for the purchase.  (Id. ¶ 40.)  As a condition of the funding, Gehl required 
Gleason to sign a Second Amended and Restated Bylaws.  (Id.)  The new bylaws 
provided, in part, that if a shareholder ceased being a director, then Xtraction was 

required to purchase the shareholder’s shares.  (Id.)  The new bylaws also expanded the 
Board of Directors from three to four.  (Id. ¶¶ 41-42.)  Gleason alleges that “[o]nce 
again,” Gurnee and Gehl represented to Gleason that “he would be rewarded for his time 
and efforts in expanding Xtraction and increasing its profits.”  (Id. ¶ 43.)  
    Gurnee and Gleason made efforts to expand Xtraction to other states.  (Id. ¶ 38.)  

Gleason alleges that he and Gurnee “regularly discussed strategy for an East Coast 
expansion.”  (Id. ¶ 77.)  Gehl and Gurnee discussed with Gleason “potentially forming a 
new limited liability company for Xtraction’s expansion to the East Coast.”  (Id. ¶ 82.)  In 
August 2020, Gurnee indicated that he would be dedicating most of his time to 
“expansion and growth.”  (Id. ¶ 86.)  Gleason alleges that Gurnee and Gehl feigned 
interest in expanding Xtraction “to take advantage of Mr. Gleason’s extensive business 
and engineering experience” and in furtherance of their “secret plans to start a competing 

business to Xtraction.”  (Id. ¶¶ 89-90.)                                  
    In July 2021, Gleason’s employment was terminated.  (Id. ¶ 47.)  Following his 
termination, Gleason discovered that Gurnee and Gehl started a new mattress recycling 
company.  (Id. ¶ 54.)  The new company, Gehl, Gurnee, & Young (“GGY”), was 
registered with the Minnesota Secretary of State in August 2021.  (Id. ¶ 55.)  GGY 

currently does business in Rhode Island and Connecticut.  (Id.)  Gleason alleges that 
Gurnee and Gehl “used Xtraction’s property, contacts, business model, and goodwill to 
create a competing business for themselves that was solely created to cut out Mr. 
Gleason.”  (Id. ¶ 57.)  Gleason also has not been compensated for his shares in Xtraction.  
(Id. ¶ 51.)                                                               

    Gleason asserts numerous claims against the defendants, including breach of 
partnership agreement, breach of fiduciary duty, fraud, intentional interference with 
contractual relations, intentional interference with prospective economic advantage, 
breach of contract, restitution, violation of Labor Code § 2802, and violation of 
California Business Professions Code §17200.1                             




1    In November 2023, the California court granted Gleason leave to amend his 
§ 17200 claim, but Gleason indicated that he intends to dismiss the claim.  (Doc. No. 20 
at 7.)                                                                    
    C.   Procedural Posture                                              
    Gleason moves to dismiss this case, involving the Loan, for forum non conveniens, 
or, in the alternative, to stay the proceedings.  Gleason asserts that this case significantly 

overlaps with the California action.  Gehl acknowledges in his Complaint that Gleason’s 
ownership interest in Xtraction “is currently being litigated in California” (Compl. ¶ 41), 
but he asserts that this action is distinct from the California action.  Moreover, Gehl 
asserts that Gleason is bound by a forum-selection clause.                
                          DISCUSSION                                     

    Gleason moves to dismiss this case based on the doctrine of forum non 
conveniens.  “‘The principle of forum non conveniens permits a court to decline 
jurisdiction even though venue and jurisdiction are proper’ because the action should 
instead be tried in another judicial forum.”  United Fire & Cas. Co. v. Weber, Inc., 
434 F. Supp. 3d 729
, 733 (D. Minn. 2020) (quoting Mizokami Bros. of Ariz. v. Mobay Chem. 

Corp., 
660 F.2d 712, 717
 (8th Cir. 1981)).                                
    The Court considers a number of factors under the doctrine of forum non 
conveniens, including private and public interest factors.  Private-interest factors “include 
relative ease of access to sources of proof, the cost of obtaining attendance of willing 
witnesses, and other practical issues that can make litigation of a case more feasible.”  
Id.
  

Public-interest factors include “the administrative difficulties flowing from court 
congestion; the local interest in having localized controversies decided at home; and the 
interest in having the trial of a diversity case in a forum that is at home with the law.”  
Id.
 
(quoting Atl. Marine Const. Co. v. U.S. Dist. Ct. for W. Dist. of Tex., 
571 U.S. 49
, 62 n.6 
(2013)).  The party seeking transfer bears the burden of proof to show that the balance of 
factors “strongly” favors the movant.  United Mortg. Corp. v. Plaza Mortg. Corp., 
853 F. Supp. 311, 315
 (D. Minn. 1994).                                           

    A valid forum-selection clause, however, changes the forum non conveniens 
analysis.  “A valid forum-selection clause should be given controlling weight in all but 
the most exceptional cases.”  Enerplus Res. (USA) Corp. v. Wilkinson, 
865 F.3d 1094
, 
1097 n.5 (8th Cir. 2017) (internal quotations and citation omitted).  A forum-selection 
clause “may be set aside if it is unjust, unreasonable, or invalid due to fraud or 

overreaching.”  Wells Fargo Fin. Leasing, Inc. v. Orlando Magic, Ltd., 
431 F. Supp. 2d 955, 961
 (S.D. Iowa 2006).  When there is a valid forum-selection clause, “the court must 
disregard consideration of private factors” when applying the forum non conveniens 
doctrine.  United Fire & Cas. Co., 434 F. Supp. 3d at 733.                
I.   Forum-Selection Clause                                               

    All the loan documents—the Promissory Note, Guarantee, and Pledge—contain 
forum-selection clauses.  Gleason breezes over the forum-selection clauses in his initial 
briefing.  And for the first time in his reply brief, Gleason alleges that the forum-selection 
clauses are invalid because they are the product of fraud.  “The party resisting 
enforcement of a valid forum selection clause bears a heavy burden in convincing the 

Court that it should not be held to its bargain.”  Zamora Ent., Inc. v. William Morris 
Endeavor Ents., L.L.C., 
667 F. Supp. 2d 1032, 1039
 (S.D. Iowa 2009).  Forum-selection 
clauses are prima facie valid and will be given effect unless the party opposing the clause 
makes a “strong showing that it should be set aside.”  Carnival Cruise Lines, Inc. v. 
Shute, 
499 U.S. 585, 591
 (1991) (internal quotations and citation omitted). 
    “[A] forum-selection clause in a contract is not enforceable if the inclusion of that 

clause in the contract was the product of fraud or coercion.”  Marano Enters. of Kan. v. 
Z-Teca Rests., L.P., 
254 F.3d 753
, 757 (8th Cir. 2001) (internal quotations and citation 
omitted) (emphasis in original).  In the California action, Gleason alleges that over 
twenty defendants, including Gehl, fraudulently induced him to invest time and effort 
into Xtraction and undercut Xtraction’s business endeavors by secretly forming a new 

company in direct competition with Xtraction.  (CA Compl. ¶¶ 89-93.)      
    Gleason asserts that the loan documents, including the Guaranty and Pledge, were 
executed, in part, based on Gehl and the other defendants’ false assertions that they 
planned to “develop Xtraction, including expanding operations outside California.”  
(Doc. No. 29 at 4.)  The complaint in the California action, however, does not explain the 

purpose of the Loan or the facts surrounding Gleason’s decision to sign the Guaranty and 
Pledge.  In fact, the complaint does not mention the Guaranty or Pledge at all.  The 
complaint does allude to certain funding provided by Gehl to finance the purchase of a 
separate California mattress recycling and disposal company in late 2020—around the 
same time the Loan was executed.  (See CA Compl. ¶¶ 39-40.)  If this is the same loan at 

issue here, then these facts seem to contradict Gleason’s assertion that the defendants’ 
stated intention to expand Xtraction was false, as it appears that the purchase of the other 
California mattress recycling company was successful.  (CA Compl. ¶ 45.)   
    Nonetheless, it is not clear to the Court whether the financing by Gehl referenced 
in the California complaint is related to the Loan at issue in this case.2  Other than a 
conclusory assertion that this Loan was “necessarily” the “product of fraud” (Doc. No. 29 

at 4), Gleason offers no specifics about the Loan, how Gleason was induced by fraud to 
sign the Guaranty and Pledge, or how the fraud specifically relates to the forum-selection 
clauses.  See Marano, 254 F.3d at 757 (noting that the complaint “d[id] not even remotely 
suggest that the [forum-selection] clauses were inserted into the agreements as the result 
of fraud”).  Gleason’s general assertion that he “was induced by fraud” to sign the 

Guaranty and Pledge “is insufficient to raise an issue that the forum-selection clauses 
within those agreements may be unenforceable because of fraud.”  Id.; see also Elliott v. 
Manhattan Cryobank, Inc., No. 19-cv-190, 
2019 WL 1318565
, at *2 (E.D. Mo. Mar. 22, 
2019) (“[G]eneral allegations of fraud in the inducement are insufficient to raise an issue 
that the forum-selection clause may be unenforceable because of fraud.”). 

    A forum-selection clause may also be set aside if enforcement of the clause would 
mean that a party would “for all practical purposes be deprived of his day in court.”  M/S 
Bremen v. Zapata Off-Shore Co., 
407 U.S. 1, 18
 (1972).  Here, neither party argues that 
they would be deprived of their day in court if required to litigate this action here.  The 
Court therefore concludes that the forum-selection clause is valid.       




2    Gehl acknowledged at the hearing that the Loan was indeed executed to purchase 
the California mattress company referenced in the California complaint; however, neither 
party mentioned this in the pleadings, briefings, or declarations.        
II.  Public-Interest Factors                                              
    Because the forum-selection clause is valid, the Court must “disregard 
consideration of private factors” when applying the forum non conveniens doctrine.  

United Fire & Cas. Co., 434 F. Supp. 3d at 733; see also Atl. Marine Const. Co., 
571 U.S. at 64
 (holding that a court must “deem the private-interest factors to weigh entirely 
in favor of the preselected forum” when there is a valid forum-selection clause).  Public-
interest factors will rarely overcome a forum-selection clause, and the forum-selection 
clause should be enforced in all but “unusual cases.”  Atl. Marine Const. Co., 
571 U.S. at 64
.                                                                    
    Gleason argues that the public-interest factors support dismissal because “all of 
the facts relevant to this proceeding . . . are all the subject matter of the California 
Action.”  (Doc. No. 29 at 5.)  As the Court noted above, facts surrounding the Loan 
specifically are not being litigated in the California action, and the California complaint 

does not even mention the Pledge or Guaranty.  Gleason further argues that he lives in 
California and the facts underlying Gehl’s claims arose in California.  But this showing is 
not enough to demonstrate that the public interest factors overwhelmingly support 
dismissal.  Moreover, as Gehl asserts, Minnesota law will govern this action, and this 
Court is in a better position to apply Minnesota law.  Overall, Gleason has not met his 

heavy burden of demonstrating that this is an unusual case that warrants dismissal despite 
a valid forum-selection clause.                                           
III.  Stay                                                                
    Lastly, Gleason argues that the Court should stay this action pending resolution of 
the California action.  The Colorado River abstention doctrine “permits federal courts to 

decline to exercise jurisdiction over cases where ‘parallel’ state court litigation is 
pending, meaning that there is ‘a substantial likelihood that the state proceeding will fully 
dispose of the claims presented in the federal court.’”  Spectra Commc’ns Grp., L.L.C. v. 
City of Cameron, 
806 F.3d 1113, 1121
 (8th Cir. 2015) (quoting Cottrell v. Duke, 
737 F.3d 1238, 1245
 (8th Cir. 2013)).  The Court is doubtful that the California action will 

dispose of any of the issues in this case, as the California action does not involve 
litigation related to liability under the Loan.3  Colorado River abstention is only 
applicable “where the surrender of federal jurisdiction is supported by the clearest of 
justification.”  
Id.
 (internal quotations and citation omitted).  Gleason has not provided a 
sufficient basis to support a stay under Colorado River.  To the extent necessary, 

however, the Court will work with the California state court to coordinate discovery and 
otherwise streamline the proceedings, if possible.                        
                         CONCLUSION                                      
    For the reasons outlined above, the Court denies Gleason’s motion to dismiss.  



3    The California action does involve litigation regarding Gleason’s ownership of his 
shares of Xtraction.  These are the same shares that Gleason pledged in the Pledge 
Agreement.  But Gleason’s liability under the Loan and Gehl’s right to Gleason’s shares, 
should Gleason be deemed the owner, are separate issues and will not be addressed in the 
California action.                                                        

ORDER

    Based upon the foregoing, and the files, records, and proceedings herein, IT IS 
HEREBY ORDERED that Defendant James Gleason’s motion to dismiss for forum non 

conveniens, or, in the alternative, to stay proceedings (Doc. No. [18]) is respectfully 
DENIED.                                                                   

Dated:  April 9, 2024         s/Donovan W. Frank                          
                             DONOVAN W. FRANK                            
                             United States District Judge                

Reference

Status
Unknown