Material Outside Complaint Can Be Considered In Motion Relating To Contractual Forum Selection Clause

In Steiner Transocean Limited v. Efremova (3D12-2390), the Third District decided that there is no reason a motion to dismiss based upon a contractual forum selection clause should be treated differently than a motion to dismiss for improper venue. Therefore, the trial court erred in refusing to consider evidence outside the four corners of the complaint for purposes of determining the validity of the motion to dismiss.