Reyes v. Home Clean Home Inc.
1:24-cv-09078
S.D.N.Y.Dec 2, 2024Background
- Plaintiff Jessica Reyes brought suit against Home Clean Home Inc. and Nicole Levine, alleging violations of labor and civil rights laws during her employment as a secretary.
- The claims were asserted under the Fair Labor Standards Act, New York Labor Law, New York State Human Rights Law, and New York City Human Rights Law.
- Reyes resides in the Bronx (Southern District of New York), while both Defendants reside and operate their business in Brooklyn (Eastern District of New York).
- The alleged violations and all operative events occurred at Defendants’ place of business in the Eastern District of New York.
- The suit was initially filed in the Southern District of New York, but the Court, on its own motion, considered whether transfer to the Eastern District was appropriate for convenience and in the interests of justice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appropriate venue for the action | Prefers SDNY | Reside/do business in EDNY | Transfer to EDNY proper |
| Deference owed to plaintiff’s choice of forum | Operative events irrelevant to location | Operative facts center in EDNY | Less deference; events centered in EDNY |
| Convenience of parties and witnesses | No major inconvenience | More convenient in EDNY | Balance favors EDNY for convenience |
| Applicability of transfer under § 1404(a) | Should remain in SDNY | Court should transfer | Transfer granted under § 1404(a) |
Key Cases Cited
- Corley v. United States, 11 F.4th 79 (2d Cir. 2021) (district courts have broad discretion to transfer cases for convenience and in the interest of justice)
- D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (guides factors for transfer under § 1404(a))
- Zepherin v. Greyhound Lines Inc., 415 F. Supp. 2d 409 (S.D.N.Y. 2006) (less deference to plaintiff’s forum choice where operative facts are in another district)