Bush v. Rust-Oleum Corporation, 3:20-cv-03268

Plaintiff Anthony Bush is a California resident who purchased Rust‑Oleum cleaning products in Emeryville (N.D. Cal.).
He alleges the products were mislabeled as 'non‑toxic' and 'earth friendly' in violation of California consumer‑protection laws and brings a putative class action limited to California residents.
Defendant Rust‑Oleum is incorporated in Delaware with its principal place of business and headquarters in Vernon Hills, Illinois (N.D. Ill.).
Rust‑Oleum moved to transfer the action to the Northern District of Illinois under 28 U.S.C. § 1404(a).
The parties agree the case could have been brought in N.D. Ill.; the dispute focused on convenience and interests of justice.
The magistrate judge denied the motion to transfer, keeping the case in the Northern District of California.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper venue for transfer under § 1404(a)	Case is properly in N.D. Cal.; plaintiff resides here and purchased products here	Case could be transferred because defendant is headquartered in N.D. Ill.	Court: no dispute transfer could be made, but transfer not warranted on convenience/justice grounds
Weight of plaintiff's choice of forum	Bush's forum choice should be given significant weight (he lives here; class limited to CA)	Plaintiff's choice deserves less weight in class actions; defendant has stronger contacts in Illinois	Court: plaintiff's choice retains significant weight; no evidence of forum shopping; favors keeping case in N.D. Cal.
Convenience of parties and witnesses	Plaintiff and putative class are in CA; operative facts occurred here	Witnesses, evidence, and corporate records are more convenient in Illinois	Court: defendant failed to show inconvenience outweighed plaintiff/class interests; factor does not favor transfer
Public‑interest factors / interests of justice	Local interest in adjudicating CA consumer claims and neutral court congestion	Illinois has an interest given defendant HQ	Court: public‑interest factors favor CA (local interest); congestion neutral; transfer denied

Piper Aircraft Co. v. Reyno, 454 U.S. 235 (U.S. 1981) (explains § 1404(a) in relation to forum non conveniens)
Norwood v. Kirkpatrick, 349 U.S. 29 (U.S. 1955) (§ 1404(a) as revision of common‑law doctrine)
Stewart Org. v. Ricoh Corp., 487 U.S. 22 (U.S. 1988) (courts assess transfers on case‑by‑case convenience and fairness)
Jones v. GNC Franchising, Inc., 211 F.3d 495 (9th Cir. 2000) (lists private‑ and public‑interest factors for § 1404(a) analysis)
Lou v. Belzberg, 834 F.2d 730 (9th Cir. 1987) (plaintiff's choice of forum generally entitled to great weight)
Decker Coal Co. v. Commonwealth Edison Co., 805 F.2d 834 (9th Cir. 1986) (public‑interest factors include local interest and court congestion)
Commodity Futures Trading Comm’n v. Savage, 611 F.2d 270 (9th Cir. 1979) (burden on moving party to show transfer appropriate)
Westinghouse Elec. Corp. v. Weigel, 426 F.2d 1356 (9th Cir. 1970) (district court has broad discretion on transfer motions)
E & J Gallo Winery v. F. & P. S.p.A., 899 F. Supp. 465 (E.D. Cal. 1994) (outlines statutory transfer requirements under § 1404(a))