Filed: Jun. 21, 2012
Latest Update: Jun. 21, 2012
Summary: MEMORANDUM OPINION AND ORDER CARLTON W. REEVES, District Judge. The Federal Rules of Civil Procedure are not mere suggestions, but neither do they exist for their own sakes. Their core purpose is to facilitate the administration of justice. 1 In this case, venue does not lie with this Court, and because of that mistake, Rule 12 of the Federal Rules of Civil Procedure permits the Court to dismiss this case. But ultimately, justice is better served by declining to dismiss the case, and this Co
Summary: MEMORANDUM OPINION AND ORDER CARLTON W. REEVES, District Judge. The Federal Rules of Civil Procedure are not mere suggestions, but neither do they exist for their own sakes. Their core purpose is to facilitate the administration of justice. 1 In this case, venue does not lie with this Court, and because of that mistake, Rule 12 of the Federal Rules of Civil Procedure permits the Court to dismiss this case. But ultimately, justice is better served by declining to dismiss the case, and this Cou..
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MEMORANDUM OPINION AND ORDER
CARLTON W. REEVES, District Judge.
The Federal Rules of Civil Procedure are not mere suggestions, but neither do they exist for their own sakes. Their core purpose is to facilitate the administration of justice.1 In this case, venue does not lie with this Court, and because of that mistake, Rule 12 of the Federal Rules of Civil Procedure permits the Court to dismiss this case. But ultimately, justice is better served by declining to dismiss the case, and this Court hereby exercises its broad discretion2 and transfers this action to the Northern District of Alabama for further proceedings.
William Watson is a resident of Lauderdale County, Mississippi, and from 2006 to 2011, he worked for Earthbound Holding, LLC.3 While working at a store owned by the company in Florence, Alabama, he was fired,4 and he brought suit in the Southern District of Mississippi for race discrimination under Title VII.
But Title VII contains a special venue provision which establishes that venue is proper only
in any judicial district in the State in which the unlawful employment practice is alleged to have been committed, in the judicial district in which the employment records relevant to such practice are maintained and administered, or in the judicial district in which the aggrieved person would have worked but for the alleged unlawful employment practice[.]5 Watson's residence is this case's only meaningful connection to Mississippi:
Earthbound's principal place of business is in Dallas, Texas,6 and Watson's firing took place in Florence, Alabama.7 Therefore, Earthbound moved8 for dismissal on the basis of improper venue.9 In the alternative, Earthbound asked that the case be transferred to the Northern District of Texas, where its principal place of business is located.10
Aside from mentioning that he once worked at one of the defendant's Mississippi stores,11 Watson offers no rebuttal to Earthbound's argument that the Southern District of Mississippi is an improper venue for this case.12 Instead, as an alternative to dismissal, Watson argues that the case should be transferred to the Northern District of Alabama, where his termination occurred.13 Earthbound opposes that request.14
"[B]ut the interest of justice countenances against dismissal[.]"15 In this case, Watson's decision to file suit in the Southern District of Mississippi appears to be, at worst, an oversight. Therefore, the Court declines to dismiss the case and finds that the interest of justice compels a transfer.16
That leaves only the question of where the matter should be transferred. Both of the parties' proposals are proper venues: the unlawful employment practice is alleged to have been committed in the Northern District of Alabama, and according to Earthbound, the employment records relevant to Watson's termination are maintained in the Northern District of Texas.17
Of the two, the Northern District of Alabama better serves this case's public and private interests. Transferring the case to the division where Watson's termination occurred will serve "the local interest in having localized interests decided at home."18 That forum also will be more convenient to witnesses such as Watson's co-workers and supervisors. And although records of Watson's employment might be housed in Texas, modern technology minimizes the logistical burden of delivering them to Alabama for Earthbound's defense.19
Therefore, Earthbound's motion to dismiss is denied. This matter is transferred to the Southern Division of the Northern District of Alabama.
SO ORDERED.
