Americraft Carton Inc. v. White Pigeon Paper Co., 2:19-cv-02090

Americraft Carton, Inc. (Missouri corp.; principal place in Kansas) sued White Pigeon Paper Co. (Michigan corp.; principal place in Michigan) for breach of contract, alleging defective paperboard and $556,512 in damages.
Case removed from Johnson County, Kansas to federal court under diversity jurisdiction.
Before answering, White Pigeon moved to transfer the case to the Western District of Michigan, arguing this court lacks personal jurisdiction and invoking 28 U.S.C. § 1631.
Americraft opposed the jurisdiction argument implicitly but filed a separate motion consenting to transfer under 28 U.S.C. § 1404(a).
Parties agreed White Pigeon manufactured the paperboard in the Western District of Michigan and most likely witnesses are in that district or in Tennessee; Americraft also operates a facility in that Michigan district.
The court concluded that transfer under § 1404(a) was appropriate and granted Americraft’s motion; White Pigeon’s motion was denied as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case should be transferred to the Western District of Michigan	Consents to transfer under § 1404(a); transfer is not unduly inconvenient and will be efficient	Sought transfer on grounds of lack of personal jurisdiction (invoking § 1631)	Transfer granted under § 1404(a); White Pigeon’s jurisdictional transfer motion denied as moot
Whether personal jurisdiction must be litigated before transfer	Implicitly disputed defendant’s lack-of-jurisdiction claim but still consented to transfer to avoid jurisdictional dispute	Argued Kansas court lacks personal jurisdiction due to insufficient contacts	Court avoided jurisdictional merits by granting § 1404(a) transfer, obviating need for jurisdictional discovery
Convenience of parties and witnesses	Argued Michigan transfer is convenient; Americraft has facility in that district	Argued no meaningful contacts with Kansas, pointing to Michigan convenience	Court found witnesses and proof largely located in Michigan/Tennessee and transfer promotes efficiency
Interest of justice / efficiency	Transfer would streamline resolution and avoid protracted jurisdictional dispute	Transfer would place litigation in defendant’s home district	Court found § 1404(a) transfer serves interests of justice and judicial economy

Emp’rs Mut. Cas. Co. v. Bartile Roofs, Inc., 618 F.3d 1153 (10th Cir. 2010) (lists § 1404(a) private- and public-interest factors for transfer)
Chrysler Credit Corp. v. Cty. Chrysler, Inc., 928 F.2d 1509 (10th Cir. 1991) (articulates considerations for transferring venue under § 1404(a))