J.L. Turner Legal Association et al. v. National Bar Association, Inc.

Background

Plaintiffs filed the action on October 14, 2025, alleging that voting for officers at the National Bar Association’s annual meeting on July 29, 2025, did not follow the Association’s governing documents, Constitution, and Bylaws. Plaintiffs also moved for a temporary restraining order, an emergency order intended to prevent or require action before a later hearing. They sought relief before an Association Board meeting scheduled for October 16–18, 2025, in New York City, arguing that the officers involved had been elected through tainted procedures and were not lawfully elected.

The complaint stated that the National Bar Association was incorporated under Iowa law, had its principal place of business in Washington, D.C., and held the annual meeting in Chicago, Illinois. Plaintiffs alleged that venue—the legally proper federal court location for the case—existed in the Southern District of New York because the Association conducted substantial operations and governance activities there. They also asserted, without further supporting allegations, that a substantial part of the events giving rise to their claims occurred in the district.

Court’s Analysis

The court applied 28 U.S.C. § 1391(b), which permits a civil action to be brought where a defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred. The court concluded that the complaint did not establish either basis in New York. The Association’s business activities in New York did not make it a resident of the state for venue purposes. The court also found that the relevant alleged injury arose from voting procedures at the Chicago annual meeting, not from the upcoming Board meeting in New York City.

Because plaintiffs had not shown that venue was proper in the district, the court held that they had not shown the likelihood of success required for a temporary restraining order. The opinion did not decide whether the Association’s election procedures violated its governing documents.

Disposition

The court denied plaintiffs’ motion for a temporary restraining order without prejudice. It directed plaintiffs to file a letter by October 31, 2025, explaining why venue was proper in the Southern District of New York and, if it was not, whether the case should be transferred under 28 U.S.C. § 1406(a).