Reyes v. Tru by Mur, Inc.

Background

The plaintiffs brought claims under the Fair Labor Standards Act, a federal wage-and-hour law, and the New York Labor Law. They sued Tru by Mur, Inc. and Igor Fazylov in the Southern District of New York.

During mediation, the plaintiffs learned that the underlying facts took place in Nassau County. They told the court that the case should have been filed in the Eastern District of New York and that they intended to seek permission to amend the complaint to add parties who lived there. The defendants' position, as reported in the plaintiffs' letter, was that the case should be transferred because the additional defendants the plaintiffs intended to name lived in the Eastern District.

Transfer Analysis

The court explained that federal law allows a case to be transferred for the convenience of the parties and witnesses and in the interest of justice. It considered the relevant transfer factors, including the convenience of witnesses and parties, the location of the events, access to evidence, the parties' resources, the plaintiff's choice of forum, trial efficiency, and the interests of justice.

The court found transfer appropriate because the parties jointly requested it. The plaintiffs' claims arose from their employment at Tru by Mur, a restaurant in Lawrence, New York, in Nassau County and the Eastern District. The court concluded that the key events occurred there and that relevant witnesses, documents, and other evidence were likely to be there. It also stated that the defendants resided in the Eastern District, making venue proper there.

Ruling

Judge Analisa Torres ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The order addressed the location of the case only; it did not resolve the merits of the plaintiffs' wage claims.