Martin Ray Winery, Inc. v. Hughes
- Jon Tigar
- 4:25-cv-02925
- U.S. District Court · Northern District of California
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Martin Ray Winery v. Hughes, Judge Tigar denied defendants’ venue motion without prejudice and stayed the injunction proceedings and discovery.
Martin Ray Winery, Inc., Phoenix Wine Company, LLC, Cameron Hughes, and The Négociant were affected by the ruling, which changed the briefing schedule and paused the preliminary-injunction proceedings and discovery.
What happened
Martin Ray Winery, Inc. sued Cameron Hughes, and later added Phoenix Wine Company, LLC as a plaintiff and The Négociant as a defendant. The plaintiffs then sought a preliminary injunction.
The defendants moved to dismiss under Rule 12(b)(3), arguing that the case should proceed in another forum, and asked to extend deadlines, postpone the injunction hearing, and pause discovery. The court denied that dismissal motion without prejudice, meaning the defendants could file a new motion based on forum non conveniens. The court also stayed the preliminary-injunction proceedings and discovery under the conditions described in its order.
Judge Jon S. Tigar ruled that Rule 12(b)(3) was not the proper method for seeking dismissal based on a contractual venue provision when federal venue is proper. The defendants could file a new forum non conveniens motion by July 18, 2025; otherwise, they had to oppose the preliminary-injunction motion by that date.
The detailed version
- Martin Ray Winery, Inc. v. Hughes · No. 4:25-cv-02925
- Jon Tigar
- July 7, 2025
Background
Martin Ray Winery, Inc. began the action against Cameron Hughes on March 28, 2025. On June 12, 2025, Martin Ray Winery, Inc. filed an amended complaint adding Phoenix Wine Company, LLC as a plaintiff and The Négociant as a defendant. The plaintiffs filed a motion for a preliminary injunction the next day.
On June 25, 2025, the defendants filed a motion to dismiss under Federal Rule of Civil Procedure 12(b)(3). The next day, they filed an administrative motion asking the court to extend briefing deadlines, continue the hearing on the preliminary-injunction motion, and stay discovery while the dismissal motion was pending. The plaintiffs opposed that administrative motion.
Court’s Analysis
The court explained that when a party seeks dismissal in favor of a nonfederal forum, the proper procedure is the doctrine of forum non conveniens. It held that Rule 12(b)(3) was not the proper vehicle for asserting a contractual provision governing venue because, when venue is proper under federal venue rules, the contract may select either a federal or nonfederal forum.
The court also noted the plaintiffs’ contention that the defendants had not engaged in scheduling discussions in good faith. The court stated that this conduct could, in other circumstances, warrant denial of an administrative motion to extend deadlines. Nevertheless, the court found that resolving the defendants’ venue challenges before hearing the preliminary-injunction motion would conserve the parties’ and the court’s resources.
Ruling
The court denied the defendants’ motion to dismiss without prejudice as to refiling a motion to dismiss on forum non conveniens grounds. Any such motion had to be filed by July 18, 2025.
The court stayed the plaintiffs’ preliminary-injunction motion pending resolution of any refiled motion to dismiss, provided that the defendants filed that motion by July 18, 2025. If the defendants did not file a new dismissal motion by that date, they had to file their opposition to the preliminary-injunction motion by July 18, 2025, and the plaintiffs’ reply would be due 14 days later. The court also stayed discovery pending resolution of any refiled dismissal motion or until further order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.