Davis v. Combs
- Laura Swain
- 1:25-cv-04740
- U.S. District Court · Southern District of New York
- 4
In Davis v. Combs, Chief Judge Swain transferred the pro se action from New York to Texas because the alleged events occurred there.
Tremeka Davis’s case was moved from the Southern District of New York to the Southern District of Texas. The named defendants remain parties to the transferred action, but the opinion did not decide whether Davis’s allegations have merit.
What happened
In Davis v. Combs, Tremeka Davis, representing herself, alleged that the defendants violated her rights in Houston, Texas. She filed the action in the Southern District of New York.
The court determined that venue did not appear proper in New York because the defendants were not all residents of New York and the alleged events occurred in Houston, in the Southern District of Texas. The court also found that transferring the case would be appropriate because the events occurred there and Davis resides there.
Chief Judge Laura Taylor Swain ordered the case transferred to the Southern District of Texas. The New York court closed the case, directed that no summons issue from that court, and denied permission to appeal without prepaying fees.
The detailed version
- Davis v. Combs · No. 1:25-cv-04740
- Laura Swain
- June 16, 2025
Background
Tremeka Davis filed this action without a lawyer, alleging that Sean Combs, Shawn Carter, Christopher B. Bridges, Gabourey Sidibe, Gregory Williams, Thomas Dexter Jakes, Sr., and Beyonce Knowles violated her rights in Houston, Texas. Davis resides in Houston. The opinion also notes that she filed another action naming many of the same defendants.
Venue and Transfer
The court explained that federal law generally permits a civil action to be filed where all defendants reside in the same state, where a substantial part of the events occurred, or, in some circumstances, where a defendant is subject to the court’s personal jurisdiction. The court stated that venue did not appear proper in the Southern District of New York based on the defendants’ residences because Davis appeared to identify defendants as residents of New York, Texas, Georgia, and California. Venue also did not appear proper there based on the events because Davis alleged that they occurred in Houston, in Harris County, Texas.
The court found that the action could properly have been brought in the Southern District of Texas because the alleged events occurred in Harris County. It then considered whether transfer was appropriate 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 interest of justice. The court concluded that transfer was appropriate because the underlying events occurred in Harris County, where Davis resides.
Ruling
Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the Southern District of Texas. The order closed the case in the Southern District of New York, stated that a summons would not issue from that court, and left the question of whether Davis could proceed without prepaying filing fees to the transferee court. The court also certified that any appeal would not be taken in good faith and denied permission to appeal without prepaying fees.
Effect of the Order
The order moved the case to the Southern District of Texas; it did not decide the merits of Davis’s allegations.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.