Declan Flight, Inc. v. Textron eAviation, Inc.

Two aircraft sales intermediaries sued Textron and Textron eAviation in the Middle District of Florida for tortiously interfering with their contracts with Slovenian manufacturer Pipistrel and with a separate Florida-law sales contract with Mesa Airlines. The district court let the non-signatory Textron entities invoke the Pipistrel contracts' Slovenian forum-selection clauses under federal common law equitable estoppel and dismissed for forum non conveniens under Atlantic Marine. The Eleventh Circuit reversed, holding that the applicability (as opposed to enforceability) of a forum-selection clause is a substantive question of contract interpretation governed by the law of the contract ">bars non-signatory enforcement here " and also reversed the district court's finding of personal jurisdiction on the Mesa-contract count.

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