Lyman v. Gas Gathering Specialists, Inc.

Background

Gas Gathering Specialists, Inc. moved under 28 U.S.C. § 1404(a) to transfer the case from the District of Minnesota to the Western District of Texas, Midland/Odessa Division. The court held a hearing on May 19, 2022, and granted the motion from the bench. This written order briefly summarized the reasons stated at the hearing.

Court’s analysis

For a venue-transfer motion, the court considered the convenience of the parties and witnesses and the interests of justice. The party requesting transfer had the burden of showing that these factors favored the proposed venue.

The court found that the relevant factors, except for the plaintiff’s choice of forum, strongly favored transfer. The only connection to Minnesota was that William Lyman worked there for two of the 36 months at issue. Lyman did not reside in Minnesota, and the opinion states that none of the witnesses or evidence was there. The substantial majority of the witnesses and evidence were in Texas, making Texas more convenient.

The court also found that continuing the case in Minnesota could create a substantial risk of conflicting judgments with a very similar action pending in the Western District of Texas. The cases involved substantially the same class members, defendants, and factual and legal issues. The court further found that transfer would avoid wasting judicial and party resources because the defendant’s offices and both parties’ counsel were located in Texas.

The court gave Lyman’s choice to sue in Minnesota little or no weight. It noted that Lyman lived in Iowa, that the underlying events did not occur in Minnesota, and that the case was brought as a nationwide class action. The court concluded that any deference given to his choice of forum could not overcome the other factors favoring transfer.

Disposition

Judge Katherine Menendez ordered that Gas Gathering Specialists, Inc.’s motion to transfer venue was granted. Venue was transferred to the United States District Court for the Western District of Texas, Midland/Odessa Division. The order addressed venue only and did not decide the merits of the underlying claims.