Coleman v. Long Island Railroad Company

Background

Anthony Coleman brought one claim against Long Island Railroad Company under the Federal Employers’ Liability Act, a federal law concerning certain railroad-employee injury claims. The opinion states that the personal injury occurred at an employee-only train station in the Eastern District of New York, where Coleman worked and where Long Island Railroad Company operates a railroad system.

Transfer Standard

The court considered transfer under 28 U.S.C. § 1404(a), which permits a federal district court to move a case to another district where it could have been brought when doing so would be more convenient for the parties and witnesses and would serve the interests of justice. Courts may consider the plaintiff’s choice of forum, witness convenience, access to documents and other evidence, party convenience, where the important events occurred, the ability to require unwilling witnesses to attend, and the parties’ relative resources.

Court’s Analysis

The court gave less weight to Coleman’s choice of the Southern District of New York because he resides in the Eastern District. It also gave that choice less weight because the important events occurred in the Eastern District. The court reasoned that relevant documents, witnesses, and methods for obtaining evidence were therefore likely to be located there. On balance, the factors favored transfer.

Disposition

The court directed the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. Judge Jennifer L. Rochon concluded that the transfer was in the interests of justice and served the convenience of the parties and witnesses.