Soto v. United Airlines, Inc.

Background

Roger Soto, whom the opinion identifies as a United flight attendant, challenged United’s COVID-19 vaccination policy. Soto sought a religious exemption. He alleged that United then placed him on an unpaid, unprotected, and unelected leave of absence. His complaint asserted California-law claims for wrongful termination and assault.

Soto initially filed the case in the Eastern District of California in September 2023. That court transferred the case to the Northern District of California in May 2024 after finding that venue was improper in the Eastern District of California and that transfer to the Northern District of California was appropriate. United later filed a renewed motion to dismiss or, alternatively, to transfer the case to the Northern District of Illinois.

Soto did not timely respond to the renewed motion. After the court ordered him to explain why the motion should not be granted, he responded and filed his opposition. The court discharged that order because Soto ultimately filed an opposition and United did not appear to have incurred additional expenses from the delay. The court criticized Soto’s counsel for missing court deadlines and stated that counsel should comply with future deadlines.

Transfer Analysis

The parties agreed that the case should be transferred to the Northern District of Illinois under 28 U.S.C. § 1404(a), a federal law allowing transfer for the convenience of the parties and witnesses and in the interest of justice. The court found that Soto could have initially filed the case in that district because United has its principal place of business there.

The court also found that transfer would promote convenience and the interests of justice. United stated that the challenged vaccination policy was adopted and implemented from its headquarters in Chicago, and that relevant witnesses and documents were located there. The court also noted that several other lawsuits concerning the same policy were being litigated in the Northern District of Illinois.

Ruling

The court held that transfer was appropriate. It granted in part and denied in part United’s motion, directed the Clerk to transfer the case to the Northern District of Illinois, and closed the case in the Northern District of California.

The court did not decide the merits of United’s request to dismiss the complaint. It denied the motion to dismiss without prejudice to renewing that request before the Northern District of Illinois. Thus, the opinion did not decide whether Soto’s claims succeed or whether they should ultimately be dismissed.