Williams v. Insomnia Cookies, LLC

Background

Michael Williams and Jonn Gibson sued Insomnia Cookies, LLC and Serve U Brand, Inc., alleging violations of federal and Missouri wage-and-hour laws. The plaintiffs worked as general managers of Insomnia Cookies stores in Missouri. The court had directed them to explain why the case should not be transferred to the United States District Court for the Eastern District of Missouri because the events and omissions underlying their claims appeared to have occurred in Missouri.

Arguments About Transfer

The plaintiffs opposed transfer on three grounds: New York was their chosen forum, they expected key witnesses to be located in New York because the defendants were headquartered there, and their lawyers were located in New York. The court rejected each argument. It stated that the plaintiffs' choice of forum received less weight because New York was neither their home nor the place where the operative facts occurred. It also noted that the plaintiffs did not identify any specific New York witnesses. The court reasoned that the key witnesses in a routine wage-and-hour case were likely people who worked directly with the plaintiffs, and that those witnesses were in Missouri. The court further held that the location of counsel was irrelevant to the transfer decision.

Ruling

Applying the convenience and interests-of-justice factors under 28 U.S.C. § 1404(a), the court found that Missouri was more convenient for the parties and witnesses, was the location of the operative facts, and had a court more familiar with Missouri law. The court ordered the case transferred to the United States District Court for the Eastern District of Missouri and directed the Clerk of Court to close the case in the Southern District of New York. It also canceled the August 2, 2023 initial pretrial conference.