Staggert v. Team Oil Tools LP
4:17-cv-02077
S.D. Tex.May 18, 2017Background
- Plaintiff Scott Staggert (resident of South Dakota; worked for Team Oil Tools May 2013–Apr 2015) sued for unpaid overtime under the FLSA, Ohio wage law, and Pennsylvania wage law, asserting class/collective claims and several opt-in plaintiffs.
- Staggert alleges he primarily worked in Ohio and Pennsylvania and was based out of a Marietta, Ohio location; he claims overtime was not paid because he was misclassified as exempt.
- Defendant Team Oil Tools LP is a Texas limited partnership with its principal place of business in The Woodlands, Texas; payroll, personnel, and management decisions (and most relevant documents) are located in Texas; no Ohio office since April 2015.
- Defendant moved to dismiss for improper venue or, alternatively, to transfer the case to the Southern District of Texas under 28 U.S.C. §§ 1391 and 1404(a).
- The court found venue proper both in the Southern District of Texas (defendant’s residence/principal place) and in the Southern District of Ohio (substantial part of events occurred there because Staggert worked overtime in Ohio), but concluded Texas is the more convenient forum and ordered transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper venue in Ohio under §1391(b)(2) | Staggert: substantial events occurred in Ohio where he worked and was based | Team Oil: residence and principal operations are in Texas; Ohio connection is conclusory | Court: Venue proper in Ohio because plaintiff alleged substantial work and overtime occurred in Ohio |
| Proper venue in Texas under §1391(b)(1)/(c)(2) | Staggert did not dispute Texas residency | Team Oil: resides and is headquartered in Southern District of Texas | Court: Venue proper in Texas because Team Oil is resident there |
| Burden of proof when venue challenged | Staggert: N/A (relied on pleadings) | Team Oil: moved to dismiss/transfer; defendant bears burden to show transfer warranted | Court: plaintiff bears initial burden to show venue proper; for transfer, movant (Team Oil) must show by preponderance that transfer is appropriate |
| Transfer for convenience under §1404(a) (forum non conveniens factors) | Staggert: Ohio witnesses and well-site nonparty witnesses located in Ohio; records associated with Marietta location | Team Oil: decisionmakers, payroll, documents, and most key witnesses are in Texas; two opt-in plaintiffs are in Texas; Texas counsel available | Court: Balance favors transfer to Southern District of Texas — majority of key witnesses and records in Texas; plaintiff’s forum choice given little weight (plaintiff is not a resident and asserts nationwide class) |
Key Cases Cited
- First of Mich. Corp. v. Bramlet, 141 F.3d 260 (6th Cir. 1998) (venue proper in any forum with a substantial connection to the claim)
- Reese v. CNH Am. LLC, 574 F.3d 315 (6th Cir. 2009) (district courts have broad discretion under §1404(a) to weigh convenience and interests of justice)
- Means v. U.S. Conference of Catholic Bishops, 836 F.3d 643 (6th Cir. 2016) (plaintiff’s choice of forum loses weight when plaintiff is not a resident of chosen forum)
- Hefferan v. Ethicon Endo-Surgery Inc., 828 F.3d 488 (6th Cir. 2016) (forum-deference principles when plaintiff files outside home forum)
- Phelps v. McClellan, 30 F.3d 658 (6th Cir. 1994) (convenience and interest-of-justice factors guide transfer analysis)
- Stewart Org., Inc. v. Ricoh Corp., 487 U.S. 22 (1988) (convenience factors include accessibility of evidence and witness availability)
- Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981) (forum non conveniens principle that foreign-plaintiff forum choice is given less deference)
- Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (1947) (plaintiff’s forum choice should not be disturbed unless balance strongly favors defendant)
- Audi AG & Volkswagen of Am., Inc. v. Izumi, 204 F. Supp. 2d 1014 (E.D. Mich. 2002) (court may consider facts outside complaint when resolving venue challenges)