Thyssenkrupp Materials NA, Inc. v. M/V Kacey
Plaintiff Thyssenkrupp Materials NA, Inc. brought an admiralty action against M/V Kacey, SPV 1 LLC, and Technomar Shipping Co. Inc. for cargo loss and damage. Defendants moved to dismiss for forum non conveniens based on a forum selection clause in the bills of lading, which stipulated disputes be decided in the carrier's principal place of business. The court addressed the plaintiff's arguments regarding the unenforceability of the clause, specifically concerning the inability to pursue in rem actions under Greek law and claims against Technomar. The court found that the Hague-Visby Rules would preserve the plaintiff's substantive rights for in rem claims and that an "Identity of Carrier" clause already precluded an in personam action against Technomar in this court. Consequently, the defendants' motion to dismiss was granted, and the plaintiff's complaint was dismissed. The court also declined to retain jurisdiction.