Robinson v. Kings County Hospital Center Health & Hospitals
- Laura Swain
- 1:24-cv-07899
- U.S. District Court · Southern District of New York
- 4
In Robinson v. Kings County Hospital Center Health & Hospitals, Judge Swain transferred this employment case to the Eastern District of New York for venue reasons.
Darrylyn V. Robinson’s lawsuit was moved from the Southern District of New York to the Eastern District of New York; the transferee court will decide whether she may proceed without prepaying filing fees.
What happened
Darrylyn V. Robinson v. Kings County Hospital Center Health & Hospitals involves Robinson’s claims under the Age Discrimination in Employment Act, the Americans with Disabilities Act, and state and local law. Robinson, who is representing herself, sued Kings County Hospital Center and Access Staffing LLC in the Southern District of New York.
The court concluded that the Eastern District of New York was a proper and more convenient place for the case. The alleged events occurred at Kings County Hospital in Kings County, the defendants are located in Kings and Suffolk Counties, and relevant witnesses were expected to be there.
Judge Laura Taylor Swain ordered the case transferred to the Eastern District of New York and closed the case in the Southern District of New York. She also ruled that the Southern District would not issue a summons and denied permission to appeal without prepaying fees.
The detailed version
- Robinson v. Kings County Hospital Center Health & Hospitals · No. 1:24-cv-07899
- Laura Swain
- Oct. 18, 2024
Background
Darrylyn V. Robinson brought this action without a lawyer, asserting claims under the Age Discrimination in Employment Act of 1967, the Americans with Disabilities Act of 1990, and state and local law. The defendants are Kings County Hospital Center and Access Staffing LLC. The opinion states that Robinson resides in New Jersey; Kings County Hospital Center is located in Kings County, New York; and Access Staffing LLC is located in Suffolk County, New York.
Venue Analysis
The court explained that the general federal venue statute applies to Robinson’s Age Discrimination in Employment Act claims. Venue is the legally proper location for a lawsuit. The court said venue in the Southern District of New York did not appear proper because the defendants were located in counties within the Eastern District of New York and the alleged employment events occurred at Kings County Hospital in Kings County, outside the Southern District.
The court found that the Eastern District of New York was a proper venue for all of Robinson’s federal claims. The Age Discrimination in Employment Act claims could be heard there based on the defendants’ locations and the place where the alleged events occurred. The Americans with Disabilities Act claim could also be heard there because the alleged unlawful employment practice occurred in New York.
Transfer Decision
Under 28 U.S.C. § 1404(a), a court may transfer a case for the convenience of the parties and witnesses and in the interest of justice. The court determined that transfer was appropriate because the underlying events occurred in Kings County, all defendants were located in the Eastern District, and relevant witnesses could reasonably be expected to be there. Robinson’s choice of the Southern District received less weight because she did not reside there and her claims did not arise there.
Order
Judge Laura Taylor Swain directed the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The order states that the transferee court would decide whether Robinson could continue without prepaying filing fees. The Southern District would not issue a summons, and the order closed the case in that district. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.