Davis v. Combs
- Laura Swain
- 1:25-cv-04753
- U.S. District Court · Southern District of New York
- 3
In Davis v. Combs, Judge Swain transferred Davis’s action from New York to Texas because the alleged events occurred in Houston.
Tremeka Davis’s action against the named defendants was transferred from the Southern District of New York to the Southern District of Texas. The transfer court did not decide the underlying allegations, and the transferee court was left to decide whether Davis could proceed without prepaying fees.
What happened
In Davis v. Combs, Tremeka Davis, representing herself, sued Sean Combs and several other defendants, alleging that events violating her rights occurred in Houston, Texas. She resides there.
The court said venue could be proper in the Southern District of Texas because the alleged events occurred in Houston. It also concluded that Texas appeared more convenient because the events occurred there and relevant witnesses and documents would reasonably be expected to be there.
Judge Laura Taylor Swain ordered the case transferred to the Southern District of Texas under the federal convenience-transfer law. The case was closed in the Southern District of New York, that court would not issue a summons, and the court denied fee-free status for any appeal.
The detailed version
- Davis v. Combs · No. 1:25-cv-04753
- Laura Swain
- June 17, 2025
Background
Tremeka Davis brought this action without a lawyer against Sean Combs, Shawn Carter, Christopher B. Bridges, Thomas Dexter Jakes, Sr., Gregory Williams, Michael Davis, and Beyonce Knowles. She alleged that the defendants violated her rights in Houston, Texas, and the opinion states that she resides in Houston.
The court noted that Davis did not allege where any defendant resides. It also noted that she had filed another action naming many of the same defendants, and that the court had transferred that action to the Southern District of Texas in an order dated June 16, 2025.
Reason for Transfer
Federal law permits a civil action to be brought in a district where a substantial part of the events giving rise to the claims occurred. Because Davis alleged that the events occurred in Houston, the court concluded that venue would be proper in the Southern District of Texas. The court stated that this was true even if it assumed that venue was also proper in the Southern District of New York based on the defendants’ residence.
The court applied the federal law allowing transfer for the convenience of the parties and witnesses and in the interest of justice. It determined that transfer appeared appropriate because the underlying events occurred in Houston, Davis resides there, and relevant documents and witnesses could reasonably be expected to be there. The court found that the Southern District of Texas appeared to be the more convenient forum.
Disposition
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 closes the case in the Southern District of New York; it does not decide the substance of Davis’s allegations. The court stated that the transferee court would decide whether Davis could proceed without prepaying filing fees. No summons would issue from the Southern District of New York. 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 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.