Research Automation, Inc. v. Schrader-Bridgeport International, Inc.
2010 U.S. App. LEXIS 24033
| 7th Cir. | 2010Background
- Two mirror-image lawsuits were filed in Illinois and Virginia over the same contract for a High Pressure Water Jet Deburr and Cleaning Machine.
- Research Automation delivered the machine to Schrader-Bridgeport in Virginia; dispute over meeting contract specs arose.
- Virginia suit (Schrader-Bridgeport) and Illinois suit (Research Automation) were removed to federal courts, forming parallel actions.
- Illinois granted Schrader-Bridgeport’s transfer motion under 28 U.S.C. § 1404(a) to Virginia; Research Automation sought an injunction to prevent transfer.
- The district court denied the injunction and transferred the Illinois action to the Western District of Virginia; appeal followed.
- The Seventh Circuit affirmed, upholding the transfer and the denial of the injunction as a reasonable, discretionary weighing of § 1404(a) factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1404(a) transfer was an abuse of discretion | Research Automation argues the first-filed forum should control the transfer. | Schrader-Bridgeport argues transfer should be decided by a holistic § 1404(a) analysis, not strictly by filing order. | No abuse; transfer upheld based on factors balancing convenience and justice. |
| Whether first-to-file governs the decision in mirror-image suits | First-filed Illinois case should control or have priority. | Courts may depart from first-to-file where transfer factors justify it. | First-to-file is not controlling; factors under § 1404(a) govern, and priority may be deemphasized. |
| Does the district court’s balancing of § 1404(a) factors support Virginia | Illinois is more convenient due to proximity of some evidence and witnesses. | Virginia has greater nexus to contract formation, performance, and testing events. | Yes; factors favored Virginia, and the district court acted within its discretion. |
| Is pendent appellate jurisdiction proper to review the transfer ruling | Not necessary to review under the first-to-file framework. | Intertwined injunction and transfer rulings warrant appellate review. | The combined rulings are reviewable on appeal; court treated them as intertwined and affirmed. |
Key Cases Cited
- Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22 (1988) (§1404(a) transfer discretion is case-by-case with convenience and fairness)
- Van Dusen v. Barrack, 376 U.S. 612 (1964) (transfer must honor forum state's law and avoid prejudice)
- Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981) (deference to balancing of public and private factors; no precise rule)
- Martin v. Graybar Electric Co., 266 F.2d 202 (7th Cir. 1959) (no rigid rule; discretion in forum selection and transfer)
- Tempco Electric Heater Corp. v. Omega Engineering, Inc., 819 F.2d 746 (7th Cir. 1987) (first-to-file rule is not binding when equity demands departure)
- Asset Allocation & Management Co. v. Western Employers Insurance Co., 892 F.2d 566 (7th Cir. 1989) (first-file rule is not a rigid mandate; transfer considerations apply)