Davis v. Combs, 4:25-cv-02983

Tremeka Davis, a resident of Houston, Texas, filed a pro se lawsuit in the Southern District of New York against several high-profile defendants, alleging rights violations that occurred in Houston.
The complaint does not specify the defendants’ residences but makes clear that all alleged conduct occurred in Houston, Texas (within the Southern District of Texas).
The case was initially filed in New York, but the court considered whether it was the appropriate venue under federal venue statutes.
The court evaluated both potential proper venue under 28 U.S.C. § 1391 and discretionary transfer under 28 U.S.C. § 1404(a) for the convenience of parties and witnesses, and in the interest of justice.
The court determined that the Southern District of Texas is the more appropriate forum and transferred the case accordingly.
The court denied in forma pauperis status for any appeal from this order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper venue for action	Events occurred in Houston	Not stated	Venue proper in Texas as events occurred in Houston
Transfer in the interest of justice	Not opposed/transferee preferred	Not stated	Transfer appropriate under §1404(a) to Southern District of Texas
Issuance of summons by New York court	Implied request for summons	Not stated	Summons not issued; case closed in New York
Leave to proceed in forma pauperis on appeal	Implied right to appeal	Not stated	Denied; appeal not in good faith

D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (district courts have broad discretion regarding convenience transfer under § 1404(a))
N.Y. Marine and Gen. Ins. Co. v. LaFarge No. Am., Inc., 599 F.3d 102 (2d Cir. 2010) (listing factors to be considered in transfer of venue analysis)
Coppedge v. United States, 369 U.S. 438 (1962) (defining standard for appeal in forma pauperis)
Keitt v. N.Y. City, 882 F. Supp. 2d 412 (S.D.N.Y. 2011) (restating venue transfer factors)