Davis v. Combs
1:25-cv-04753
S.D.N.Y.Jun 17, 2025Background
- Plaintiff Tremeka Davis, a Houston, Texas resident, brought a pro se action in the Southern District of New York.
- Davis alleges that several defendants, including Sean Combs, Shawn Carter, Christopher B. Bridges, Thomas Dexter Jakes Sr., Gregory Williams, Michael Davis, and Beyonce Knowles, violated her rights in Houston, Texas.
- No information was provided about the defendants’ residences; however, Davis’s complaint centers on events occurring in Houston.
- The Court considered where the alleged events occurred and where parties and evidence are likely located.
- The procedural posture: The case was originally filed in New York, but the Court considered transferring it prior to any substantive proceedings.
- Another related action by Davis against the same defendants was also transferred to the Southern District of Texas the prior day.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper venue for lawsuit | Suit can proceed in SDNY | Not addressed | Venue more appropriate in S.D. Texas |
| Transfer for convenience and justice | Not directly addressed | Not addressed | §1404(a) supports transfer given facts/resources |
| Issuance of summons/prepayment status | Entitled to proceed | Not addressed | Transfer; further fee rulings reserved for Texas |
| Appeal in forma pauperis status | Possibly entitled | Not addressed | Appeal in forma pauperis would not be in good faith |
Key Cases Cited
- D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (district courts have broad discretion under § 1404(a) for convenience and fairness of venue transfer)
- N.Y. Marine and Gen. Ins. Co. v. LaFarge No. Am., Inc., 599 F.3d 102 (2d Cir. 2010) (sets forth factors for deciding motions to transfer venue)
- Coppedge v. United States, 369 U.S. 438 (1962) (standards for appeal in forma pauperis)
- Keitt v. N.Y. City, 882 F. Supp. 2d 412 (S.D.N.Y. 2011) (lists venue transfer factors under § 1404(a))