Chateau des Charmes Wines, Ltd. v. Sabaté USA, Inc.
United States Court of Appeals, Ninth Circuit
328 F.3d 528 (2003)
Sabaté France, through its California subsidiary Sabaté USA (defendants), sold specialty wine corks to Canadian winery Chateau des Charmes Wines (plaintiff) after the parties agreed by phone on quantity, price, and shipping terms. Sabaté's invoices, issued after the deal, specified that disputes would be litigated in France. After the wine was found tainted, Chateau des Charmes sued in California federal court for breach of contract, strict liability, and false advertising; Sabaté moved to dismiss based on the invoice forum-selection clauses, and the district court agreed and dismissed the case.
Whether a forum-selection clause printed in shipping invoices between international parties is part of a valid and enforceable sales agreement when the parties' prior oral contract did not include such a clause.