When Stewart filed suit in Alabama, Ricoh moved to transfer the case to Manhattan pursuant to the forum-selection clause.

[3] The Supreme Court remanded the case, holding that the federal venue transfer statute, 28 U.S.C.

In particular, the considerations of convenience to the parties and the fairness of the transfer in light of the parties relative bargaining power (when drafting the forum-selection clause) mandated by federal law collided with the Alabama policy categorically disfavoring forum-selection clauses, and that in the "single field of operation... the instructions of Congress are supreme."

Justice Scalia dissented from the majority opinion, arguing that there was no direct collision between § 1404(a) and Alabama's law, and that therefore the appropriate inquiry is whether the Rules of Decision Act, 28 U.S.C.

Applying the RDA analysis from Hanna v. Plumer (1965), Scalia argued that state law governed the question because venue selection would encourage forum shopping, and that the choice of venue was highly outcome determinative because "[i]t is difficult to imagine an issue of more importance, other than one that goes to the very merits of the lawsuit, than the validity of a contractual forum-selection provision."