Douglas v. Chariots for Hire
918 F. Supp. 2d 24
D.D.C.2013Background
- Douglas, a limousine driver, sues Chariots for Hire for unpaid wages under FLSA; amended to pursue collective action under §216(b).
- Defendants move to dismiss for improper venue or transfer to ED Va; DC proper venue contested.
- Court held venue proper in DC since substantial events occurred here and defendant is DC-resident.
- Key DC events include plaintiff’s DC driving time and company’s DC-oriented services, ads, and familiarity with DC.
- Court notes Virginia-centric events but DC has substantial connection; case proceeds in DC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is DC proper venue under §1391(b)(2)? | Substantial events occurred in DC; Chariots resident in DC. | Most events occurred in Virginia; DC venue improper. | DC venue is proper. |
| Should the case be transferred to ED Va under §1404(a)? | Local ties to DC counsel case here. | Virginia has stronger ties; transfer warranted. | Transfer denied; maintain in DC. |
| Should case be dismissed under §1406(a) for improper venue? | DC has substantial events; venue proper. | Virginia-dominant events mean improper venue. | §1406(a) not applicable; venue proper in DC. |
Key Cases Cited
- Shay v. Sight & Sound Sys., Inc., 668 F. Supp. 2d 80 (D.D.C. 2009) (venue depends on where substantial work performed)
- Treppel v. Reason, 793 F. Supp. 2d 429 (D.D.C. 2011) (transfer requires convenience and interests of justice)
- Dooley v. United Techs. Corp., 786 F. Supp. 65 (D.D.C. 1992) (§1391(b)(2) venue where substantial events occurred)
- Modaressi v. Vedadi, 441 F. Supp. 2d 51 (D.D.C. 2006) (DC may be proper despite others' substantial events)
- City of New York v. Cyco.Net, Inc., 383 F. Supp. 2d 526 (S.D.N.Y. 2005) (venue may be proper where substantial events occurred)