Cerami-Kote, Inc. v. Energywave Corp

In Cerami-Kote, Inc. v. Energywave Corp., 116 Idaho 56, 773 P.2d 1143 (Idaho 1989), the Idaho Supreme Court looked to Florida law when conducting an analysis of the enforceability of a forum selection clause and concluded that such clauses must be enforced, pursuant to Florida law, if "'enforcement would not contravene a strong policy enunciated by statute or judicial fiat, either in the forum where the suit would be brought, or the forum from which the suit has been excluded.'" Id. at 1146. Citing Idaho statutory authority that would render the forum selection clause unenforceable, the Cerami-Kote court struck down the clause and allowed the action to proceed in Idaho. Id. at 1147.