Hickman v. Meta Platforms, Inc.

Background

Shena Hickman, who was representing herself, sued Meta Platforms, Inc., alleging that Meta discriminated and retaliated against her because of her race, color, sex, national origin, and age. She asserted claims under Title VII of the Civil Rights Act of 1964 and the Age Discrimination in Employment Act. The opinion states that Hickman worked for Meta in Burlingame, California, from October 2017 to October 2018. It also states that Hickman alleged retaliation over the following seven years in California, Florida, and New York, including in the Southern District of New York.

Venue Analysis

Venue means the federal district where a case may properly be heard. The court explained that Title VII has a specific venue rule, while the Age Discrimination in Employment Act generally uses the federal venue statute, 28 U.S.C. § 1391. The court concluded that the Northern District of California was a proper venue for both sets of claims. The alleged employment discrimination occurred in San Mateo County, where Burlingame and Meta’s Menlo Park location are situated, and relevant employment records were likely maintained there. For the age-discrimination claims, Meta resided in the Northern District of California, and a large majority of the events appeared to have occurred in San Mateo County or Florida.

Transfer Decision

Under 28 U.S.C. § 1404(a), a court may transfer a case to another district where it could have been brought when doing so would promote the convenience of the parties and witnesses and the interests of justice. The court found transfer appropriate because Meta resides in the Northern District of California, Hickman worked there, relevant records were maintained there, many underlying events occurred there, and witnesses could reasonably be expected to be located there. The court also noted that Hickman had previously filed a similar action against Meta in that district.

Disposition

Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the Northern District of California. The order closed the case in the Southern District of New York, and a summons was not to issue from that court. The decision on Hickman’s request for the court to seek pro bono counsel and on her other motions was left to the transferee court; the Clerk was directed to terminate all pending motions. The court also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal from the order.