Williams v. Glengariff Rehabilitation Healthcare Center

Background

Latoya Williams filed this action without a lawyer. She asserted employment-discrimination and retaliation claims under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights Law. The court also understood her complaint to assert claims under 42 U.S.C. § 1981 and additional unspecified state, federal, and municipal laws.

Williams sued Glengariff Rehabilitation Healthcare Center, identified as her former employer, along with Glengariff’s supervisor of nursing, “Ms. Marlene,” and director of nursing, “Ms. Agusto.” The opinion states that Glengariff is in Glen Cove, Nassau County, New York, and that Williams alleged the events supporting her claims, including an alleged assault, occurred in Nassau County.

Venue and Transfer

The court explained that Title VII permits an employment-discrimination action to be filed in several districts connected to the alleged unlawful employment practice, including where the practice occurred or where relevant employment records are maintained. The court concluded that the Southern District of New York, as well as other federal districts in New York, was a proper venue for Williams’s Title VII claims.

For the § 1981 and state-law claims, the court said it was unclear whether venue was proper in the Southern District under the rule concerning where defendants reside because Williams did not identify where all defendants reside. Even assuming venue was proper there, the court concluded that the Eastern District was also a proper venue because the alleged events occurred in Nassau County.

Under 28 U.S.C. § 1404(a), a federal court may transfer a case to another proper federal district for the convenience of the parties and witnesses and in the interest of justice. The court determined that transfer appeared appropriate because the alleged events and defendants were in Nassau County, and relevant documents and witnesses could reasonably be expected to be there. It therefore found the Eastern District of New York to be a more convenient forum.

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. It stated that the transferee court would decide whether Williams could proceed without prepaying fees. Summonses were not to issue from the Southern District, and the order closed the action in that court.

The court also certified that an appeal would not be taken in good faith under 28 U.S.C. § 1915(a)(3), and denied Williams permission to appeal without prepaying fees. The order transferred the case and addressed filing-fee and appeal matters; it did not resolve the merits of Williams’s discrimination, retaliation, or other claims.