Jamison v. ABM Aviation Taxi Dispatch
- Laura Swain
- 1:25-cv-07756
- U.S. District Court · Southern District of New York
- 4
In Jamison v. ABM Aviation Taxi Dispatch, Judge Swain transferred the employment-discrimination case to the Eastern District of New York for convenience.
Shariff A. Jamison’s employment-discrimination case was moved from the Southern District of New York to the Eastern District of New York; the claims were not decided on their merits.
What happened
Shariff A. Jamison v. ABM Aviation Taxi Dispatch concerns employment-discrimination claims under federal and state law. Jamison filed the case without a lawyer in the Southern District of New York against his former employer.
The court said the alleged events occurred in Queens County, where ABM Aviation Taxi Dispatch is located. Although the Southern District was a proper venue for the Title VII claims, the Eastern District was also proper and appeared more convenient because the events, witnesses, and documents were likely connected to Queens.
Judge Laura Taylor Swain transferred the action to the Eastern District of New York. The Southern District case was closed, no summons was issued there, and the transferee court was left to decide whether Jamison could proceed without paying filing fees. The court also denied fee-waiver status for an appeal.
The detailed version
- Jamison v. ABM Aviation Taxi Dispatch · No. 1:25-cv-07756
- Laura Swain
- Sept. 22, 2025
Background
Shariff A. Jamison filed this action without a lawyer against his former employer, ABM Aviation Taxi Dispatch. He asserted employment-discrimination claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and state law. The opinion states that Jamison resides in Brooklyn, in Kings County, and that ABM is located in Elmhurst, in Queens County. Jamison alleged that the events supporting his claims occurred in Queens County.
Venue analysis
Venue means the federal district where a case may properly be litigated. The court explained that Title VII permits an employment-discrimination case to be filed in a district where the alleged unlawful employment practice occurred, where relevant employment records are maintained, or where the person would have worked absent the alleged discrimination, subject to the statute’s other provisions. The court concluded that the Southern District of New York and every other federal district in New York were proper venues for the Title VII claims.
For the Section 1981 and state-law claims, the court applied 28 U.S.C. § 1391(b). It concluded that the Eastern District of New York was a proper venue because a substantial part of the alleged events occurred in Queens County and the defendant is located there.
Transfer ruling
Under 28 U.S.C. § 1404(a), a court may transfer a case, even when venue is proper, to another district where the case could have been brought when doing so serves the convenience of the parties and witnesses and the interests of justice. The court considered the connection of the alleged events and the defendant to Queens County, the likely location of relevant documents and witnesses, and the fact that Jamison did not reside in the Southern District. It therefore found that the Eastern District of New York appeared to be the more convenient forum.
The court ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. It stated that the transferee court would decide whether Jamison could proceed without prepaying filing fees. No summons was to issue from the Southern District, and the order closed the case in that court. The court certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees.
Disposition
The action was transferred under 28 U.S.C. § 1404(a). The opinion did not decide the merits of Jamison’s employment-discrimination claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.