D'Anzieri v. HHarrison Global LLC

Background

The court had issued an earlier opinion and order on June 25, 2025, deciding the defendants’ motion for summary judgment and concluding that it lacked personal jurisdiction over D’Anzieri’s claims. The court then asked the parties to address whether the action should be transferred instead of dismissed and proposed transfer to the District of Massachusetts, identified as the district where Harrison Global is domiciled.

D’Anzieri consented to transfer to Massachusetts and asked for permission to respond to the defendants’ position. The defendants argued that the case should be dismissed because D’Anzieri knew or should have known that New York lacked personal jurisdiction. Alternatively, they proposed the Southern District of Florida, citing D’Anzieri’s residence there, the company’s awareness that she worked remotely there, and defense counsel’s offices there.

Court’s Analysis

The court explained that federal law permits transfer to a district that can exercise personal jurisdiction when transfer is in the interest of justice. In deciding whether transfer was appropriate, the court could consider whether the claims would be meritless in a court with jurisdiction and whether the plaintiff had acted diligently in choosing a proper forum.

The court rejected the defendants’ argument for dismissal. It found that the authorities they cited were distinguishable, that D’Anzieri had not conceded the jurisdictional issue, and that she had not engaged in forum shopping or repeatedly sought to move the case elsewhere. The court also found it reasonable for her to file in New York based on her statements and testimony that she worked remotely there and experienced the effects of the alleged discrimination there.

Although the court ultimately found that the claims could not survive the personal-jurisdiction issue in New York, it found that D’Anzieri had some basis for believing the court could exercise jurisdiction. The court noted that the jurisdiction ruling was based on undisputed evidence tending to show that the defendants did not know she worked remotely from New York, and that proving a defendant’s knowledge can be difficult without direct evidence. The court found no indication that D’Anzieri acted in bad faith and concluded that transfer would promote the efficient resolution of the nearly four-year-old case.

The court also found that the defendants had not adequately shown that the Southern District of Florida was a more appropriate transferee forum than Massachusetts. It noted that Harrison Global was neither headquartered nor organized in Florida and that the defendants had not shown sufficient contacts with Florida beyond hiring D’Anzieri, who had communicated that she resided in Florida, Georgia, and New Jersey while employed by the company.

Disposition

Judge Valerie Caproni ordered the Clerk of Court to terminate all open motions, transfer the case to the United States District Court for the District of Massachusetts, and close the Southern District of New York case. The court denied D’Anzieri’s motion for leave to respond to the defendants’ submission as moot. This order transferred the case; it did not decide the underlying discrimination claims on their merits.