Finnegan v. Uber Technologies Inc.

Background

Sean Matthew Finnegan, who was representing himself, filed an action invoking the Fair Debt Collection Practices Act against Uber Technologies Inc. and the Metropolitan Police Department. The opinion states that Finnegan alleged Uber drugged him, held him in a vehicle, drove him around Washington, D.C., drove him across state lines, and left him in a parking lot. He also alleged that the Metropolitan Police Department and the Arlington Police Department failed to respond, investigate, or produce reports.

Finnegan sought $1 billion, payment for past and future fees, costs, expenses, and damages, and an order requiring the defendants to produce documents and other information. He also asked the court to order the Metropolitan Police Department to produce a report, investigate, and arrest a suspect. The court had previously granted his request to proceed without paying filing fees at that stage.

Venue analysis

The court applied 28 U.S.C. § 1391, the federal venue statute. It explained that a civil action may generally be filed where all defendants reside, where a substantial part of the events occurred, or, if neither applies, where a defendant is subject to the court’s personal jurisdiction.

Finnegan alleged that Uber resided in New York, New York, and that the Metropolitan Police Department resided in Washington, D.C. Because the defendants were alleged to reside in different states, the court concluded that venue was not proper in the Southern District of New York under the provision concerning where defendants reside. The court also found that Finnegan had not alleged that a substantial part of the relevant events occurred in New York.

The court concluded that the District of Columbia was a proper venue because Finnegan alleged that a substantial part of the events occurred there. Under 28 U.S.C. § 1406(a), the court therefore transferred the action to the United States District Court for the District of Columbia.

Ruling

The court directed the clerk to transfer the action to the District of Columbia. It stated that a summons would not issue from the Southern District of New York and that the order closed the action in that court. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for an appeal. Judge Laura Taylor Swain directed that a copy of the order be mailed to Finnegan and that service be noted on the docket.