Pit River Tribe v. Bureau of Land Management

Background

Pit River Tribe, Native Coalition for Medicine Lake Highlands Defense, Mount Shasta Bioregional Ecology Center, and Medicine Lake Citizens for Quality Environments brought three claims under the Geothermal Steam Act and the Administrative Procedure Act. They alleged that the federal defendants unlawfully failed to terminate or modify Lease CA12372 and the Glass Mountain Unit Agreement, which concern geothermal resources in Northeastern California. The plaintiffs sought orders requiring termination of the lease and agreement and prohibiting activity based on them.

Calpine Corporation and CPN Telephone Flat, Inc., referred to collectively as the corporate defendants, moved under 28 U.S.C. § 1404(a) to transfer the case from the Northern District of California to the Eastern District of California. The Eastern District had handled earlier litigation involving the Glass Mountain Unit and related leases. In that earlier litigation, the Eastern District and the Ninth Circuit addressed the continuation of 26 nonproducing leases and ordered agency proceedings concerning whether those leases should be extended or canceled.

Analysis

The court concluded that the action could originally have been brought in the Eastern District. The disputed land is in Siskiyou County, and the court found that significant agency decisions connected to the claims occurred in an office located in that district. The plaintiffs also did not dispute that the case could have been brought in either the Northern or Eastern District.

The court then weighed convenience and the interests of justice. It determined that transfer could prevent inconsistent judgments because the earlier litigation concerned leases connected to Lease CA12372 and the Glass Mountain Unit. The federal defendants had not yet completed the agency determination ordered in the earlier case, so a decision in this case could potentially conflict with that process.

The court also found that transfer would promote judicial efficiency. The earlier litigation and the present case involved the same parties and property, and Judge Mendez was familiar with a 2013 stipulation that was central to a claim-preclusion dispute raised in this case. The court concluded that the Eastern District was better positioned to determine how the claims related to the earlier litigation. It further found that transfer would generally deter possible forum shopping, although it did not find that the plaintiffs had actually engaged in forum shopping.

The convenience factors also favored transfer. The court stated that the Pit River Tribe resided in the Eastern District and that Calpine took the position that venue there would be more convenient for it. Because the case would likely be resolved through summary judgment and written discovery rather than live testimony, witness convenience did not favor either side. The court gave the plaintiffs’ choice of the Northern District little weight because the disputed land and the alleged inaction were centered in the Eastern District. Although the Eastern District’s congestion weighed against transfer, the court found that it did not overcome the other factors.

Ruling

Judge Phyllis J. Hamilton granted the corporate defendants’ motion to transfer. The clerk was directed to transfer the action to the United States District Court for the Eastern District of California. The court terminated the federal defendants’ motion to dismiss and the corporate defendants’ conditional partial motion to dismiss without deciding them. The order did not decide the merits of the plaintiffs’ claims.