The ProImmune Company, LLC v. Lile
- Kenneth Karas
- 7:22-cv-07242
- U.S. District Court · Southern District of New York
- 2
In The ProImmune Company v. Lile, Judge Abrams ordered reassignment from Manhattan to White Plains under district rules without deciding the contract dispute.
The case’s courthouse assignment affects The ProImmune Company, LLC, Laura Lile, M.D., and Three Aminos, LLC. The order moved the case from the Manhattan courthouse to the White Plains courthouse but did not decide the contract claims.
What happened
The ProImmune Company, LLC sued Laura Lile, M.D., and Three Aminos, LLC, in a breach-of-contract case. The defendants asked to move the case from the Manhattan courthouse to the White Plains courthouse, and the plaintiff opposed the request.
The court ruled that the case belonged in White Plains under the Southern District of New York’s case-assignment rules. The court noted that the claim arose in Dutchess County and that the plaintiff’s principal place of business was there. It also rejected the plaintiff’s argument that the contract required the case to be heard in New York County because both courthouses are in the same federal district and venue.
Judge Abrams ordered that the case be reassigned to White Plains. The order addressed only the courthouse assignment and did not decide the parties’ breach-of-contract dispute.
The detailed version
- The ProImmune Company, LLC v. Lile · No. 7:22-cv-07242
- Kenneth Karas
- Sept. 2, 2022
Background
The ProImmune Company, LLC filed a breach-of-contract action against Laura Lile, M.D., and Three Aminos, LLC. The defendants asked the court to reassign the matter from the Manhattan courthouse of the Southern District of New York to the White Plains courthouse under the district’s Rules for the Division of Business Among District Judges. The plaintiff opposed the request.
Court’s Analysis
The court concluded that Rule 18 required the case’s initial designation for White Plains because the claim arose in whole or in major part in a Northern County and at least one party resided there. The court stated that Dutchess County is one of the Northern Counties. It also stated that the plaintiff did not dispute the defendants’ contentions that the plaintiff’s principal place of business was in Dutchess County and that the claim arose there.
The plaintiff argued that the defendants had agreed in the contract to the exclusive venue of any court in New York County and had agreed not to challenge venue. The court rejected that argument because the Manhattan and White Plains courthouses are both within the Southern District of New York and therefore constitute the same venue. The court also stated that a plaintiff does not have a right to have a case heard in a particular courthouse within that district.
Disposition
The court found that the interests of justice and judicial economy would be served by reassignment at the early stage of the proceeding. Judge Ronnie Abrams ordered that the case be reassigned to White Plains. The order did not resolve the underlying breach-of-contract claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.