Hamlett v. Centene Management Company, LLC
- Colleen McMahon
- 1:20-cv-08270
- U.S. District Court · Southern District of New York
- 3
In Hamlett v. Centene, Judge McMahon transferred Hamlett’s employment-discrimination case from the Southern District of New York to the Eastern District.
Jeannie Hamlett’s claims against Centene Management Company, LLC were moved from the Southern District of New York to the Eastern District of New York. The Southern District action was closed, and no summons issued from that court.
What happened
Jeannie Hamlett, representing herself, sued Centene Management Company, LLC, under federal and New York employment-discrimination laws. She alleged that Centene discriminated and retaliated against her because of her race and color and ended her employment.
The court said the claims could be filed in either New York federal district because the alleged events occurred in Queens County. It nevertheless found that transfer was appropriate because the events occurred there and relevant documents and witnesses were likely located in the Eastern District of New York.
Judge Colleen McMahon ordered the case transferred to the Eastern District of New York. The Southern District case was closed, no summons would issue there, and the court denied permission to appeal without paying filing fees.
The detailed version
- Hamlett v. Centene Management Company, LLC · No. 1:20-cv-08270
- Colleen McMahon
- Nov. 5, 2020
Background
Jeannie Hamlett, appearing without a lawyer, sued Centene Management Company, LLC. She brought claims under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. She alleged that Centene discriminated and retaliated against her based on her race and color and terminated her employment. The opinion states that Hamlett lived in Suffolk County and worked for Centene in Rego Park, Queens County.
Venue and transfer analysis
The court explained that Title VII permits an employment-discrimination claim to be filed in certain districts connected to the alleged unlawful employment practice, relevant employment records, the location where the employee would have worked, or, in some circumstances, the employer’s principal office. Because the alleged events occurred in Queens County, the court concluded that both the Southern District of New York and the Eastern District of New York were proper venues for Hamlett’s Title VII claims.
The court nevertheless considered transferring the case under 28 U.S.C. § 1404(a), which allows a federal court to move a case for the convenience of the parties and witnesses and in the interest of justice. The court said it could order a transfer on its own initiative. It considered the circumstances relevant to convenience and fairness, including the location of the events, witnesses, documents, and other sources of proof.
Ruling
Judge Colleen McMahon concluded that transfer was appropriate because the events underlying Hamlett’s claims occurred in Queens County, which is in the Eastern District of New York, and relevant documents and witnesses were likely located there. The court ordered the Clerk to transfer the action to the United States District Court for the Eastern District of New York. It also directed that no summons issue from the Southern District of New York and stated that the order closed that case.
The court certified that any appeal would not be taken in good faith and denied permission to appeal without paying the filing fee. The opinion is a venue and case-management ruling; it does not decide whether Hamlett’s discrimination or retaliation allegations are legally or factually valid.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.