Nance v. Ryder Integrated Logistics, Inc.

Background

Tiffeny Nance brought claims under California’s Private Attorneys General Act (PAGA), alleging labor-law violations by Ryder Integrated Logistics, Inc. and Ryder System, Inc., referred to in the opinion as Ryder. Nance had previously filed a proposed class action based on the same conduct in the Eastern District of California.

Ryder moved to transfer the case to the Eastern District under 28 U.S.C. § 1404(a), a statute that permits transfer when another federal district is a more appropriate venue. Ryder also relied on the first-to-file rule, which can favor the court where a related case was filed first. Nance opposed the transfer and argued that the case should instead be sent to state court because, in her view, the federal court lacked subject-matter jurisdiction.

Court’s reasoning

The court determined that transfer should be addressed before resolving the jurisdictional objection. It stated that venue could be considered first because the court could not readily determine that it lacked jurisdiction over the case. The court also noted that the federal court already handling Nance’s non-PAGA claims was best positioned to determine whether the PAGA action belonged in federal court.

The court emphasized that all events giving rise to the complaint occurred in the Eastern District of California. It also found that witnesses, documents, and other evidence were primarily located there. Nance agreed that venue was proper in that district if the court determined that federal jurisdiction existed and remand was not appropriate.

Disposition

Judge James Donato ordered transfer to the Eastern District of California. The court vacated the case-management conference scheduled for October 19, 2023. The order addressed venue and transfer; it did not decide the merits of Nance’s labor-law allegations.