Zuri Washington v. Networks Presentations, LLC, et al.
- Andrew Carter
- 1:24-cv-00299
- U.S. District Court · Southern District of New York
- 3
In Washington v. Networks Presentations, Judge Carter transferred the case to Maryland because venue was improper in New York.
Zuri Washington and the defendants in the action; the case will proceed, if otherwise appropriate, in the United States District Court for Maryland rather than the Southern District of New York.
What happened
In Zuri Washington v. Networks Presentations, LLC, et al., the court considered whether the case belonged in the Southern District of New York. Washington argued that important events occurred there, including the formation and signing of her employment contract and a decision about her hair plan.
The court found that a substantial part of the relevant events occurred elsewhere: in Utica, Philadelphia, and Denver. It also found that only one of the four corporate defendants resided in New York, while three resided in Maryland, where the defendants decided to terminate Washington. The court therefore concluded that venue was improper in New York.
Judge Andrew L. Carter, Jr. transferred the action to the United States District Court for Maryland under the federal venue-transfer law and directed the Clerk of Court to terminate a pending letter motion.
The detailed version
- Zuri Washington v. Networks Presentations, LLC, et al. · No. 1:24-cv-00299
- Andrew Carter
- Nov. 6, 2025
Background
The court had previously granted the defendants’ motion to dismiss for improper venue, while allowing Zuri Washington to file a second amended complaint. After Washington filed that complaint, the defendants submitted a letter motion about an anticipated motion to dismiss for improper venue. The court then ordered the parties to explain why the case should not be dismissed for improper venue or transferred to the District of Maryland.
Venue Analysis
Federal law generally permits a civil action to proceed in a district where a defendant resides, where a substantial part of the events or omissions giving rise to the claim occurred, or, if no other district qualifies, where a defendant is subject to personal jurisdiction.
The court rejected Washington’s argument that a substantial part of the events occurred in the Southern District of New York. It relied on the reasons given in its March 31, 2025 opinion and identified the locations of relevant events: Utica for Washington’s hair-related claims, Philadelphia for a COVID-19 meeting and communications with her agent, and Denver for the human-resources meeting and termination. Although Washington’s employment contract was formed and signed in New York, the court found that it was largely performed outside that district.
Washington also argued that venue was proper because she believed the defendants made the decision about her hair plan in New York. The court stated that, even assuming that decision was made there and was material to the other claims, it did not constitute a substantial part of the relevant acts. The court therefore found venue improper under 28 U.S.C. § 1391(b)(2). It also found venue improper under § 1391(b)(1) because only one of the four corporate defendants resided in New York, and concluded that § 1391(b)(3) did not make venue proper because another district qualified.
Ruling
Under 28 U.S.C. § 1406(a), when a case is filed in the wrong venue, a court may dismiss it or, in the interest of justice, transfer it to a district where it could have been brought. The court found that venue lay in the District of Maryland and, in the interest of justice, transferred the action there. Judge Andrew L. Carter, Jr. directed the Clerk of Court to transfer the action and terminate the pending letter motion at ECF No. 57.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.