Friedeberg v. Dollar Tree Corp.
- Laura Swain
- 1:25-cv-03996
- U.S. District Court · Southern District of New York
- 4
In Friedeberg v. Dollar Tree Corp., Judge Swain transferred the pro se case from New York to Connecticut as the more appropriate venue.
Donna L. Friedeberg and Dollar Tree Corp.; the case will proceed, if at all, in the United States District Court for the District of Connecticut rather than the Southern District of New York.
What happened
Donna L. Friedeberg sued Dollar Tree Corp. without a lawyer, based on alleged events at a Dollar Tree store in Norwich, Connecticut. The opinion does not describe the underlying claims in detail.
The court found that Connecticut was clearly a proper venue because Friedeberg lived there and the alleged events appeared to have occurred there. It was unclear whether New York was a proper venue, but the court transferred the case to the federal court in Connecticut because that court appeared more convenient.
In Friedeberg v. Dollar Tree Corp., Judge Laura Taylor Swain ordered the Clerk to transfer the action to the District of Connecticut. The order closed the action in the Southern District of New York, left any decision about proceeding without paying fees to the receiving court, and denied fee-free status for an appeal.
The detailed version
- Friedeberg v. Dollar Tree Corp. · No. 1:25-cv-03996
- Laura Swain
- June 3, 2025
Background
Donna L. Friedeberg brought this action without a lawyer against Dollar Tree Corp. Her allegations appear to arise from experiences at a Dollar Tree store in Norwich, Connecticut. The opinion notes that her complaint was not signed. The opinion does not explain the specific claims or alleged events in detail.
Venue analysis
The court applied 28 U.S.C. § 1391(b), the federal statute governing the proper location for a civil case. That statute allows a case to be filed where a defendant resides, where a substantial part of the events occurred, or, when neither of those options is available, where the defendant is subject to the court’s authority.
The court concluded that the District of Connecticut was clearly a proper venue. Friedeberg lived in Norwich, which is in that district, and she alleged facts indicating that Dollar Tree had a store there. She also appeared to allege that a substantial part of the events underlying her claims occurred in Connecticut. The court did not determine that the Southern District of New York was improper, but it said it was unclear whether New York qualified as a proper venue under the applicable statute.
Transfer decision
Under 28 U.S.C. § 1404(a), a federal court may transfer a case to another federal district where it could have been brought when the transfer would be more convenient for the parties and witnesses and would serve the interests of justice. The court reasoned that relevant documents and witnesses would likely be in Connecticut because the alleged events appeared to have occurred there. It therefore determined that the District of Connecticut appeared to be the more convenient forum.
Order
Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the District of Connecticut. The order closed the action in the Southern District of New York. It stated that the receiving court would decide whether Friedeberg could continue without prepaying filing fees, and that no summons would issue from the New York court. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.