McDonald v. JetBlue Airways Corporation
- Laura Swain
- 1:25-cv-06819
- U.S. District Court · Southern District of New York
- 4
In McDonald v. JetBlue Airways, Judge Swain transferred a pro se disability-discrimination case from the Southern to the Eastern District of New York.
Shanice McDonald and JetBlue Airways Corporation; the action will proceed, if permitted by the transferee court, in the Eastern District of New York rather than the Southern District of New York.
What happened
In McDonald v. JetBlue Airways Corporation, Shanice McDonald, representing herself, sued JetBlue under the Americans with Disabilities Act, alleging employment discrimination. She said she worked at JFK Airport and that JetBlue’s headquarters were in Queens County.
The Southern District of New York concluded that Queens County is in the Eastern District of New York. It also found that the events, witnesses, documents, and parties appeared connected to Queens, making the Eastern District a more convenient court even though the claims could be heard there.
Judge Laura Taylor Swain ordered the case transferred to the Eastern District of New York and closed the case in the Southern District of New York. She also denied fee-free status for any appeal, while leaving the decision about proceeding without paying filing fees to the Eastern District.
The detailed version
- McDonald v. JetBlue Airways Corporation · No. 1:25-cv-06819
- Laura Swain
- Aug. 19, 2025
Background
Shanice McDonald brought the action without a lawyer against JetBlue Airways Corporation. She asserted employment-discrimination claims under Title I of the Americans with Disabilities Act (ADA). McDonald stated that she worked at JFK Airport in Queens County and that JetBlue’s headquarters were in Queens County.
Venue and Transfer
The court explained that the ADA incorporates a special venue rule for employment-discrimination claims. Under that rule, an ADA claim may be brought in a district where the alleged unlawful employment practice occurred, among other locations. Because the alleged events occurred in Queens County, the court concluded that venue was proper in the Eastern District of New York. The opinion also states that Queens County is within that district.
The court then applied the federal transfer statute, 28 U.S.C. § 1404(a), which allows a court to move a case for the convenience of the parties and witnesses and in the interest of justice. The court found that transfer appeared appropriate because the underlying events occurred at JFK Airport, and it was reasonable to expect that the relevant documents and witnesses would also be in Queens County. The court further stated that all parties were located in Queens County and that the Eastern District therefore appeared to be the more convenient forum.
Disposition
The court ordered the Clerk to transfer the action to the United States District Court for the Eastern District of New York. The order closes the case in the Southern District of New York. It states that the transferee court will decide whether McDonald may proceed without prepaying fees, and that no summons will issue from the Southern District. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not decide the merits of McDonald’s ADA claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.