Bennett v. Jehovah's Witnesses

Background

Jayson S. Bennett brought this pro se action against Jehovah’s Witnesses, Watchtower Bible and Tract Society of New York, Inc., and Watch Tower Bible and Tract Society of Pennsylvania. He invoked federal-question and diversity jurisdiction. Bennett alleged, among other things, that the defendants’ teachings caused him to develop extreme political and religious beliefs, intentionally inflicted emotional distress, and caused him to suffer to the point of insanity and suicide.

Bennett alleged that he had been domiciled in West Virginia throughout his life. He identified addresses for defendants in Tuxedo Park and Patterson, New York, and alleged that a defendant’s primary place of business and residence were in New York.

Venue and Transfer

The court explained that venue was proper in the Southern District of New York under 28 U.S.C. § 1391(b)(1), based on Bennett’s allegations that one defendant was located there and that all defendants were in New York. The court also concluded that the Southern District of West Virginia was a proper venue under § 1391(b)(2) because a substantial part of the events giving rise to the claims occurred there.

Under 28 U.S.C. § 1404(a), a court may transfer a case to another proper district for the convenience of the parties and witnesses and in the interest of justice. Applying the relevant convenience factors, the court emphasized that the underlying events occurred in West Virginia, where Bennett resided, and that it was reasonable to expect the relevant documents and witnesses to be there. Because Bennett did not live in New York and the operative events did not occur there, the court gave his choice of the New York forum less weight.

Disposition

The court transferred the action to the United States District Court for the Southern District of West Virginia and directed the clerk to carry out the transfer. It stated that the transferee court would decide whether Bennett could proceed without prepaying fees. The court also ordered that no summons issue from the Southern District of New York and stated that the order closed the action in that court.

The court certified that any appeal would not be taken in good faith and denied Bennett permission to proceed without prepaying fees for purposes of an appeal. The order addressed venue and convenience; it did not decide the merits of Bennett’s allegations.