Vaughn Boyd; SWI-DE, LLC, doing business as Drew Estate v. Deadwood Tobacco Company
June 8, 2026·25-1659·Panel Decision·SMITH·By Maria Santos
The Eighth Circuit affirmed the dismissal of a trademark infringement lawsuit on forum non conveniens grounds. The court held that the claims arose from a stock purchase agreement containing a mandatory forum selection clause.
Background
Vaughn Boyd and SWI-DE, LLC sold Deadwood Tobacco Company to William and Jodene Rectenwald, reserving certain trademark rights. Disputes arose over alleged trademark infringements related to the reserved marks, leading to litigation.
The court’s reasoning
The court determined that the plaintiffs’ claims arose from the stock purchase agreement, which included a mandatory forum selection clause. The court found that the forum selection clause was valid and enforceable, and that state courts could hear claims under the Lanham Act.
What it means going forward
The ruling reinforces the enforceability of forum selection clauses in contracts and clarifies that state courts can adjudicate federal trademark claims.
