Johnson v. Deloitte Services, LLP, 939 F. Supp. 2d 1

Johnson, proceeding pro se, sues Deloitte Services, LLP and others alleging Title VII, ADA, and FMLA discrimination/retaliation.
Defendants move to dismiss for improper venue; Johnson requests transfer to the Eastern District of Virginia if venue is improper.
The Court holds District of Columbia is not a proper venue for Title VII/ADA claims, but the Eastern District of Virginia is appropriate for all claims.
Johnson worked in Deloitte’s McLean, Virginia office; meetings occurred there; she did not work in the District of Columbia.
EEOC notice issued to Johnson originated from the Washington Field Office but was copied to Deloitte’s Virginia HR office; the complaint does not place the alleged practice in DC.
The Court transfers the case to the Eastern District of Virginia in the interest of justice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is DC proper venue under 42 U.S.C. 2000e-5(f)(3) for Title VII/ADA claims?	Plaintiff contends venue may be in DC; if improper, requests transfer.	Defendant argues venue is improper in DC given work in VA and location of records.	DC not a proper venue.
Where would the aggrieved employee have worked but for the alleged practice?	Plaintiff suggests possible DC involvement due to floating role and meetings in DC.	No evidence plaintiff would have worked in DC; evidence shows VA work location.	Plaintiff fails to show would have worked in DC; not proper.
Is the fourth venue prong (principal office) applicable?	Argues Deloitte’s principal offices might justify DC venue.	Deloitte’s principal place and operations are in VA; fourth prong not applicable when other prongs fail.	Fourth prong not applicable; VA location suffices for proper venue.
Should the case be transferred rather than dismissed?	Requests transfer under 28 U.S.C. § 1404(a) and § 1406(a) in the interest of justice.	Venue is proper in VA for all claims; transfer appropriate when venue is improper.	Court transfers to ED Va; in the interest of justice, entire case transferred.

Pendleton v. Mukasey, 552 F. Supp. 2d 14 (D.D.C. 2008) (venue analysis follows liberal pleading standards and applies precedent)
Darby v. U.S. Dep’t of Energy, 231 F. Supp. 2d 274 (D.D.C. 2002) (context for venue determinations in pro se filings)
Land v. Dollar, 330 U.S. 731 (Supreme Court 1947) (treats location of claims and related considerations for venue)
Williams v. GEICO Corp., 792 F. Supp. 2d 58 (D.D.C. 2011) (venue factors in Title VII/ADA actions in D.C.)
Cheeks v. Fort Myer Constr. Co., 722 F. Supp. 2d 93 (D.D.C. 2010) (liberal pleading standards for pro se plaintiffs in venue analysis)
Khalil v. L-3 Commc’ns Titan Grp., 656 F. Supp. 2d 134 (D.D.C. 2009) (fourth venue scenario limited when other prongs apply)
McLaughlin v. Holder, 864 F. Supp. 2d 134 (D.D.C. 2012) (fourth venue prong governs when no other venue exists)
Walden v. Locke, 629 F. Supp. 2d 11 (D.D.C. 2009) (venue considerations for agency-related claims)
Donnell v. Nat’l Guard Bureau, 568 F. Supp. 93 (D.D.C. 1983) (procedural venue principles for federal claims)
James v. Verizon Servs. Corp., 639 F. Supp. 2d 9 (D.D.C. 2009) (FMLA venue considerations under general venue statute)