NEVADA IRRIGATION DISTRICT v. SOBECK, 1:20-cv-03523

Plaintiff Nevada Irrigation District (NID) owns and operates the Yuba–Bear Hydroelectric Project in Placer and Nevada Counties, California, and required a water-quality certification under Clean Water Act §401 as part of FERC license renewal.
The California State Water Resources Control Board issued a certification in August 2020 imposing conditions on NID; NID contends the Board waived its §401 authority by failing to act within one year.
FERC found the Board waived its authority; the Board petitioned for review in the Ninth Circuit, and NID intervened in defense of FERC’s decision.
NID sued in D.D.C. seeking declaratory and injunctive relief to enjoin enforcement and to vacate the certification; NID also filed a parallel state-court action in California.
Defendants moved under 28 U.S.C. §1404(a) to dismiss, transfer, or stay; the district court considered only the transfer question and concluded venue was proper in the Eastern District of California.
The court granted transfer to the Eastern District of California, finding private- and public-interest factors (including local interest and related Ninth Circuit proceedings) favor transfer and that transfer avoids duplicative, inconsistent adjudication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether venue was proper in the Eastern District of California	NID did not dispute venue but stressed D.C. forum and FERC involvement	Defendants argued all defendants and relevant events are in Eastern District	Court: Venue proper in EDCA under §1391(b)(1) (official-capacity residency) and §1391(b)(2) (events occurred there)
Whether plaintiff's choice of forum merits deference for §1404(a) transfer	NID urged deference to its forum selection in D.C.	Defendants noted both parties are "at home" in EDCA and deference is reduced when forum is not plaintiff's home	Court: Little deference given because D.C. is not NID's home and both parties are in EDCA; favors transfer
Balance of private-interest factors (witness convenience, evidence, where claim arose)	NID emphasized FERC’s role and D.C. connections	Defendants stressed project, applications, and Board action occurred in EDCA	Court: Private factors neutral-to-favor-transfer—key events and evidence in EDCA; no undue inconvenience from transfer
Public-interest factors (familiarity with law, docket congestion, local interest, related appeals)	NID noted D.D.C. competence and cited relative caseloads	Defendants relied on local interest, state-law claims, and related Ninth Circuit case reviewing FERC waiver	Court: Public factors favor transfer—state-law claims counsel for EDCA, local interest decisive, and Ninth Circuit proceedings counsel transfer to avoid duplicative/inconsistent review

Stewart Org., Inc. v. Ricoh Corp., 487 U.S. 22 (1988) (governs §1404(a) two-step transfer inquiry and discretionary factor balancing)
Trout Unlimited v. USDA, 944 F. Supp. 13 (D.D.C. 1996) (discusses deference to plaintiff's forum and local interest in water-related disputes)
Nestor v. Hershey, 425 F.2d 504 (D.C. Cir. 1969) (official-capacity public officials reside where they perform official duties for venue purposes)
Exelon Generation Co., LLC v. Grumbles, 380 F. Supp. 3d 1 (D.D.C. 2019) (distinguished: addressed venue under §1406(a), not discretionary transfer under §1404(a))
W. Watersheds Project v. Jewell, 69 F. Supp. 3d 41 (D.D.C. 2014) (case congestion statistics not dispositive; transfer appropriate despite higher caseload in transferee district)
Otay Mesa Prop. L.P. v. U.S. Dep’t of Interior, 584 F. Supp. 2d 122 (D.D.C. 2008) (local interest is important but not dispositive where issue has national concern)
Aftab v. Gonzalez, 597 F. Supp. 2d 76 (D.D.C. 2009) (district may address transfer before resolving subject-matter jurisdiction challenges)