Fairchild v. Chesky

Background

Alison Helen Fairchild brought this case against several defendants, including James Han, concerning incidents related to a short-term property rental in Riverside, California. Han filed two motions: a motion to dismiss and an unopposed motion to transfer venue.

The opinion also discusses an October 2019 order from the Central District of California declaring Fairchild and her partner, Arogant Hollywood, vexatious litigants. The opinion states that the order required them to submit a copy of that order and seek permission before filing a new civil action in that district. It also states that, on January 27, 2025, a judge in the Eastern District of California transferred a related case brought by Hollywood against Han’s wife and others to the Central District of California.

Transfer Standard

Under 28 U.S.C. § 1404(a), a federal district court may transfer a civil case to another district where it could have been brought when the transfer would serve the convenience of the parties and witnesses and the interests of justice. The court considers the circumstances of the particular case, including the parties’ and witnesses’ convenience, access to evidence, local interest, and the possibility of consolidating related claims.

Court’s Analysis

The parties did not dispute that Fairchild could have brought the case in the Central District of California. The court found that several factors favored transfer: the convenience of the parties and witnesses, access to evidence, and the local interest in the controversy. The relevant property was in Riverside, Fairchild was identified as a Riverside resident, and Han was identified as residing at the property address.

The court also found that transfer could facilitate consolidation with Hollywood’s related claims because that case had already been transferred to the Central District of California. The court gave no deference to Fairchild’s choice of the Northern District of California, finding that she had engaged in forum shopping and that the operative facts did not occur there.

Disposition

Judge Edward M. Chen granted Han’s motion to transfer venue to the United States District Court for the Central District of California under 28 U.S.C. § 1404(a). The court ordered that the case and all pending motions be transferred and directed the Clerk to close the Northern District of California action. The opinion does not state a separate ruling on Han’s motion to dismiss or decide the underlying claims.

Classification

This is a procedural order because the court resolved venue and transferred the case without deciding the merits of the claims.