Jackson v. Pilgrim Psychiatric Center

Background

Darlene A. Jackson, representing herself, brought claims under the New York State Human Rights Law and Title VII of the Civil Rights Act of 1964 against her former employer, Pilgrim Psychiatric Center, and Michael Izzano. She alleged that the defendants discriminated against her based on her religion by suspending and then terminating her employment as a managed care coordinator after she refused to receive a COVID-19 vaccine.

Jackson lives in Suffolk County, New York. The complaint stated that Pilgrim is located in Suffolk County, that Izzano resides in Albany County, and that the events underlying the claims occurred where Jackson was employed, in the Eastern District of New York. The complaint did not allege conduct connected to the Southern District of New York.

Venue analysis

The court held that the Southern District was not a proper venue for the New York State Human Rights Law claims. Under the federal venue statute, those claims could be brought where a defendant resides, where a substantial part of the relevant events occurred, or, in limited circumstances, where a defendant is subject to personal jurisdiction if no other proper district exists. The court determined that the Eastern District was a proper venue because the relevant employment and alleged discrimination occurred there, while the complaint did not establish that the Southern District was a proper venue.

The court concluded that venue for the Title VII claims was proper in both the Southern District and the Eastern District. Title VII permits an employment-discrimination action to be brought in a district within the state where the alleged unlawful employment practice occurred, among other locations.

The court also considered transfer under 28 U.S.C. § 1404(a), which permits a court to move a case for the convenience of the parties and witnesses and in the interest of justice. It found that the relevant factors favored the Eastern District. Jackson lived and worked there, the alleged discrimination occurred there, and relevant documents, evidence, and witnesses were likely located there. The court also noted that the complaint did not allege a connection to the Southern District.

Disposition

The court transferred the action to the United States District Court for the Eastern District of New York. The Clerk of Court was directed to complete the transfer and mail the order to Jackson. The opinion did not decide the merits of Jackson’s discrimination claims.