Davis v. Combs
4:25-cv-02982
| S.D. Tex. | Jun 16, 2025Background
- Plaintiff Tremeka Davis, a Houston, Texas resident, filed a pro se civil rights lawsuit against several high-profile defendants, including Sean Combs, Shawn Carter, Gabourey Sidibe, and Beyoncé Knowles.
- The complaint alleges that the events giving rise to her claims occurred in Houston, Texas (Harris County).
- Davis filed the action in the Southern District of New York, despite being a Texas resident and her claims arising in Texas.
- The named defendants allegedly reside in New York, Texas, Georgia, and California.
- The court reviewed whether venue was appropriate in the Southern District of New York and considered transfer for convenience and in the interest of justice.
- The court ultimately ordered the case transferred to the Southern District of Texas, closing the case in New York.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper Venue | Venue is proper in SDNY (implied) | Venue improper; events in Texas | Venue improper; transfer to SDTX |
| Events Location | Harm occurred (unspecified) | Key events in Houston, TX | Events occurred in Houston, TX |
| Residence of Defendants | Some defendants reside in NY | Defendants reside in multiple states | Not all defendants reside in NY |
| Convenience and Justice | Plaintiff chose SDNY | More convenient in SDTX | Transfer promotes convenience/justice |
Key Cases Cited
- D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (district courts have broad discretion under Section 1404(a) in determining convenience and fairness for transfer)
- Iragorri v. United Tech. Corp., 274 F.3d 65 (2d Cir. 2001) (plaintiff’s choice of forum given less weight if they do not reside there and events did not occur there)
- N.Y. Marine and Gen. Ins. Co. v. Lafarge No. Am., Inc., 599 F.3d 102 (2d Cir. 2010) (factors to consider in venue transfer decisions)