Background
Meadow Ridge owns and operates gas wells in Wetzel County, West Virginia. Under a 2020 agreement, Eureka was the exclusive gas gatherer for certain Meadow Ridge wells. That agreement selected Harris County, Texas, as the forum for disputes, while an earlier gathering agreement selected Kanawha County, West Virginia.
After Meadow Ridge notified Eureka in June 2025 that it intended to use a different gatherer, Eureka sought a temporary restraining order in Texas. Meadow Ridge then filed parallel petitions in Kanawha County for declaratory relief and an anti-suit injunction to stop the Texas proceeding. The circuit court denied the injunction and dismissed the declaratory-judgment petition, concluding that the Texas forum-selection clause deprived it of subject-matter jurisdiction.
The Court’s Holding
The Intermediate Court of Appeals reversed and remanded. It held that the circuit court erred by treating the forum-selection clause as a limit on subject-matter jurisdiction.
Forum-selection clauses concern venue, not a circuit court’s authority to hear a category of case, the court explained. West Virginia circuit courts are courts of general jurisdiction, and the Kanawha County Circuit Court therefore had jurisdiction over this contract dispute. The appellate court did not decide which forum-selection clause governs, whether Texas is the proper forum, or any other issue raised below.
Key Takeaways
- A forum-selection clause does not strip a West Virginia circuit court of subject-matter jurisdiction.
- Forum selection concerns venue rather than the court’s general power to adjudicate a civil dispute.
- The merits of the competing forum-selection clauses remain for the circuit court on remand.
Why It Matters
The decision draws a clear procedural line: a contractual forum provision may affect where a case should proceed, but it does not eliminate a West Virginia circuit court’s jurisdiction over an otherwise cognizable dispute. Parties challenging litigation based on a forum-selection clause must frame and resolve that issue as one concerning venue or contractual enforcement, not subject-matter jurisdiction.