Gulf Restoration Network v. Jewell, 87 F. Supp. 3d 303

Gulf Restoration Network challenged multiple agencies’ approval of the Gulf State Park Enhancement Project under the APA, NEPA, and OPA.
The Project is located on Alabama state land in Gulf State Park and involves a hotel, convention center, research/education facilities, and recreational/ecological enhancements.
Defendants sought transfer under 28 U.S.C. § 1404(a) to the Southern District of Alabama, arguing local interest and factors favor transfer.
The Deepwater Horizon Spills restoration framework and a multi-agency Trustee Council governed early restoration planning and project selection.
The Alabama Trustees played a key role in identifying and advancing the Project through Phase III, including public meetings and Executive Committee processes.
Final approval occurred on October 2, 2014 with the ROD and a Stipulation with BP, signed by both federal trustees and Alabama representatives.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether transfer to Alabama was proper under § 1404(a).	Gulf Restoration argues transfer is improper or premature given forum deference and connections.	Defendants contend Alabama has a stronger local interest and proper venue given project location and impacts.	Transfer granted after balancing interests; local Alabama interest outweighed factors supporting retention.
Whether the plaintiff’s forum choice deserves substantial deference.	Gulf Restoration asserts strong deference due to DC Trustee involvement.	Plaintiff is not headquartered in DC; deference is diminished.	Plaintiff’s forum deference is only substantial but not controlling; transfer still favored.
Whether the private-interest factors favor transfer.	Alabama ties are minimal beyond site location and state involvement.	Alabama actors influenced project; decision-making occurred across multiple locations.	Private-interest factors collectively favor transfer due to localized impact and Alabama involvement.
Whether the public-interest factors favor transfer.	No strong local interest in DC vs. Alabama.	Local Alabama interest in decision at home is significant.	Local interest in Alabama decisively favors transfer.

Trout Unlimited v. U.S. Dep’t of Agric., 944 F. Supp. 13 (D.D.C. 1996) (two-step transfer analysis; burden on movant under § 1404(a))
Wilderness Soc’y v. Babbitt, 104 F. Supp. 2d 10 (D.D.C. 2000) (private/public-interest factors; transfer considerations)
Stand Up for California! v. U.S. Dep’t of Interior, 919 F. Supp. 2d 51 (D.D.C. 2013) (local interest and transfer rationale)
Piper Aircraft Co. v. Reyno, 454 U.S. 235 (U.S. 1981) (presumption of forum deference; diminished where foreign plaintiff)
Oceana v. Bureau of Ocean Energy Mgmt., 962 F. Supp. 2d 70 (D.D.C. 2013) (localized impact and transfer considerations)
Defenders of Wildlife v. Salazar, No. 12-1833, slip op. at 6 (D.D.C. 2013) (essentially neutral third factor; nationwide effects balanced)
Otay Mesa Property L.P. v. U.S. Dep’t of Interior, 584 F. Supp. 2d 122 (D.D.C. 2008) (local population injury considerations; transfer suitability)
Adams v. Bell, 711 F.2d 161 (D.C. Cir. 1983) (local interests relevant to portable decisions)
Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (U.S. 1947) (local considerations in venue decisions)