Soto v. United Airlines, Inc.

Background

Roger Soto sued United Airlines, Inc., alleging assault and wrongful termination based on his refusal to receive a COVID-19 vaccine because of sincerely held religious beliefs. Soto alleged that United required employees to become fully vaccinated by September 27, 2021, or face termination. He submitted a request for a religious accommodation and alleged that United ultimately granted a religious exemption but placed him on unpaid leave without benefits or a specified return date. He also alleged that the vaccine requirement caused him to fear harmful and offensive contact and invaded his privacy and bodily integrity.

United moved to dismiss for failure to state a claim, lack of personal jurisdiction, and improper venue. In the alternative, United asked the court to transfer the case to Chicago, Illinois, where it said the company was headquartered.

Personal Jurisdiction

The court denied United’s motion to dismiss for lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b)(2). It found that United was not subject to general jurisdiction in California because the opinion identified Illinois and Delaware, rather than California, as the places where United was at home for that purpose.

The court nevertheless found specific jurisdiction. It determined that United purposefully directed activities toward California or purposefully conducted business there through its hubs at Los Angeles International Airport and San Francisco International Airport. The court also concluded that Soto’s claims arose out of or related to United’s enforcement of its vaccine mandate at its California hubs, particularly the San Francisco hub. Because United did not argue that exercising jurisdiction would be unreasonable after Soto satisfied the first two parts of the analysis, the court concluded that United had waived that argument.

Venue and Transfer

The court agreed with United that venue was improper in the Eastern District of California. It found that United was not domiciled there and that a substantial part of the events or omissions did not occur there. The relevant locations identified in the opinion included Chicago, Illinois, and San Francisco International Airport in the Northern District of California.

Under 28 U.S.C. § 1406(a), a court may dismiss a case filed in the wrong district or transfer it to a district where it could have been brought when transfer serves the interests of justice. The court concluded that transfer was appropriate because United’s policies had effects in California and California had an interest in providing a forum for protecting its residents. It also found no apparent bad faith in Soto’s filing in the Eastern District, noting that Soto lived within that district.

The court therefore denied United’s motion to dismiss under Rule 12(b)(3) and § 1406(a), but granted United’s motion to transfer venue. It ordered that the case be transferred to the Northern District of California.

Rule 12(b)(6) Motion

The court declined to reach the merits of United’s motion to dismiss under Rule 12(b)(6), which concerned whether Soto’s complaint stated a legally sufficient claim. The court directed the parties to contact the assigned chambers in the Northern District of California for further instructions about that motion.

Disposition

The court granted in part and denied in part United’s Motion to Dismiss or in the Alternative to Transfer Venue. Specifically, it denied the motions to dismiss under Rules 12(b)(2) and 12(b)(3), granted the motion to transfer venue, and declined to decide the Rule 12(b)(6) motion. The court vacated all dates and deadlines set before it, directed the Clerk to transfer the case documents to the Northern District of California, and closed the case in the Eastern District of California.