Stilwell v. Northwell Health, Inc.

Background

Stilwell sued Northwell Health, Inc., Northwell Health, Inc. doing business as Huntington Hospital, and Joseph Volavka. He alleged violations of Title VII, the Age Discrimination in Employment Act (ADEA), and the New York State Human Rights Law. According to the complaint, Stilwell worked for Northwell for twenty-two years, mostly at Huntington Hospital. In 2023, he interviewed for Director of Food and Dining Services, but Northwell selected another candidate. Stilwell alleged that the decision was based on his age, sex, and sexual orientation, and that he was fired three weeks after complaining about the decision. He also alleged retaliation for opposing discrimination.

The events described in the complaint occurred in the Eastern District of New York. The opinion states that Stilwell and Volavka reside there, Huntington Hospital is located there, and Northwell is headquartered in New Hyde Park, New York.

Defendants’ Motion

The defendants moved under Federal Rule of Civil Procedure 12(b)(3) to dismiss for improper venue. Alternatively, they requested a transfer under 28 U.S.C. § 1404(a), which allows a court to transfer a case for the convenience of the parties and witnesses and in the interests of justice.

Court’s Analysis

The court explained that Title VII has a special venue rule. But Stilwell’s ADEA claim is governed by the general venue statute, 28 U.S.C. § 1391(b). The court held that venue was not proper in the Southern District of New York for the ADEA claim because all defendants resided in the Eastern District and all events relevant to the case occurred there. Because Stilwell brought multiple claims, venue had to be proper for each claim.

The court also applied the factors used for a transfer under Section 1404(a), including the plaintiff’s choice of forum, convenience to the parties and witnesses, judicial economy, and the interests of justice. It gave Stilwell’s choice of the Southern District limited weight because he and the lawsuit lacked a genuine connection to that district. The court found that the other factors favored transfer: the Eastern District was where the operative facts occurred, where all parties were located, and where depositions would likely occur. The court rejected Stilwell’s argument that the geographic proximity of courthouses in the Southern and Eastern Districts made the geographic factors neutral. It noted that the case could be litigated in the Eastern District courthouse in Central Islip because the events occurred in Nassau or Suffolk County.

Disposition

The court ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The opinion did not decide the merits of Stilwell’s discrimination or retaliation claims.