Holmes v. Chen

Background

Kiara Holmes filed a complaint naming YouTube, Alphabet Inc., Google LLC, and other defendants. The opinion states that Holmes is a citizen of Louisiana, is representing herself, and paid the filing fee. Her complaint concerns a video uploaded to YouTube and her interactions with the companies. Holmes did not know the addresses of several defendants. She identified YouTube as located in San Mateo County and Alphabet Inc. as located in Santa Clara County. For Google LLC, she identified the location of a separate entity that she described as its registered agent, Corporation Service Company, in Sacramento County.

Venue analysis

Venue is the proper federal court location for a case. Under 28 U.S.C. § 1391(b), a civil case may generally be filed where a defendant resides, where a substantial part of the relevant events occurred, or, in some circumstances, where a defendant is subject to the court’s personal jurisdiction. The court found that the defendants identified by Holmes were located in counties within the Northern District of California and that none of the events related to the Eastern District of California.

Disposition

The court stated that, in the interest of justice, a federal court may transfer a complaint filed in the wrong district to the correct district under 28 U.S.C. § 1406(a). Judge Allison Claire ordered that the matter be transferred to the United States District Court for the Northern District of California. The order transferred the case and did not resolve the merits of Holmes’s claims.