• Forum Selection Clause: appraisal fraud counterclaim against lender had no direct relationship to lot purchase contract containing forum selection clause—to which lender was not a party—and, thus, lender was not entitled to dismissal of counterclaim for improper venue -- Bahamas Sales Associate, LLC v. Byers, No. 11-11664 (reversing dismissal)
  • Equitable Estoppel: lender who was not a party to lot purchase contract with forum selection clause could not invoke equitable estoppel to enforce such clause because borrower’s counterclaim did not rely on the contract -- Bahamas Sales Associate, LLC v. Byers, No. 11-11664 (reversing dismissal)