In Luzingu v. Abbott Laboratories, Inc., (D ME, July 31, 2026), a Maine federal district court rejected a claim by a Christian pastor that in a civil rights action under Title VII and state statutes against his former employer, Abbott Laboratories, he should be able to ignore a forum selection clause in his employment agreement that requires any litigation against his employer be brought in state or federal court in northern Illinois. Plaintiff worked in an Abbott Lab facility in the state of Maine beginning in 2016 when he came to the United States from Angola because of persecution in his home country. His Abbott employment was terminated in 2022. He now is employed as a Christian pastor and is pursuing a master's degree online. He filed suit against Abbott in a Maine federal district court. According to the court:
Plaintiff argues that transfer [of the case to Illinois] would be unfair, unjust, and against public policies that favor the free exercise of religion and nondiscrimination.... Plaintiff is “the sole pastor at his church” and “leads three services per week.” ... Because of his religious calling and his duties, he maintains, “[t]raveling to Illinois for a deposition or trial would make it far more difficult for him to fulfill his pastoral duties than if the deposition or trial occurred in Maine.”...
I am not persuaded that Plaintiff’s religious practices and duties as a pastor justify giving him a special dispensation to avoid application of the Forum-Selection Clause.... And as for the burden itself, assuming that a special dispensation might be appropriate based on individual needs pertaining to the inconvenience of a particular forum, the Defendant has indicated that Plaintiff’s deposition will take place in Maine. Moreover, Defendant fairly observes that a trial in Illinois should take only a few days and that telecommunications technology enables Plaintiff to remain connected to his parishioners when court is not in session. I agree with Defendant that the limited time required to conduct a trial of this case in Illinois will not unduly disrupt Plaintiff’s religious observance, even if religious observance is a proper basis to nullify the consequences of a forum-selection clause.
... [I]t is unreasonable to suspect that Defendant is enforcing the Forum-Selection Clause against Plaintiff in a selective manner based on the burden that litigation in Illinois would impose on his pastoral duties. Defendant has similarly moved to enforce its forum-selection clause in cases brought by plaintiffs who do not point to their religious practice as cause to avoid the consequences of the Forum-Selection Clause....
