United Artists Corp. v. Masterpiece Productions, Inc.
United States District Court · 1950 · Civil Procedure
Civil ProcedureTransfer of venue28 U.S.C. § 1404(a)venue transfer1404(a)plaintiff's choice of forumconvenience of partiesconvenience of witnesses
Facts
The defendant sought transfer of the case to New York City, where its main office was located. Both parties submitted affidavits addressing convenience and justice under § 1404(a). The books, records, and witnesses were apparently located in many different parts of the country rather than concentrated in New York. The defendant maintained one of its principal exchanges in the present district, and the alleged acts could have occurred there as consistently as elsewhere.
Issue
Whether the court should transfer the action to the Southern District of New York under 28 U.S.C. § 1404(a). More specifically, the question was whether convenience and the interest of justice justified transfer despite the plaintiff's chosen forum.
Rule
Under 28 U.S.C. § 1404(a), transfer is permissible only for the convenience of parties and witnesses and in the interest of justice. A bare balance of convenience to the defendant is not sufficiently persuasive to deprive the plaintiff of its chosen forum, especially where the forum was not selected to vex, harass, or oppress the defendant and is not otherwise inappropriate.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Lakefront Media LLC sued Harbor Thread Studios in federal court in Chicago. Harbor Thread asks to transfer the case to Manhattan because its main office and senior managers are there, but the parties' records are stored in Illinois, Texas, California, and Georgia, and likely witnesses are scattered across those states as well.
How should the court rule on Harbor Thread's motion to transfer under the majority's approach?
Explanation. Section 1404(a) permits transfer only for the convenience of parties and witnesses and in the interest of justice. The majority held that it is not enough that the transferee district would be more convenient for the defendant because its main office is there. Where records and witnesses are spread across many places, the case lacks a localized center of gravity, and the plaintiff chose an otherwise appropriate forum, the plaintiff's choice should not be displaced by a mere balance of convenience favoring the defendant. (Derived from United Artists Corp. v. Masterpiece Productions, Inc. (n.d.).)