Meteoro Amusement Corp. v. Six Flags

Brief Fact Summary.

Six Flags sought to transfer suit to the Western District of Oklahoma, the Central District of California, or the Southern District of New York when Meteoro Amusement Corp. originally filed suit in the Northern District of New York.

Synopsis of Rule of Law.

A federal district court can transfer a suit to another district court with jurisdiction where the suit may have been filed originally.

Facts.

Meteoro Amusement Corp. (Meteoro) was incorporated in New Mexico with its principal place of business in New York. Metero held a patent for an amusement park ride and distribute videos of the technology to several different companies. Six Flags was one of the companies contacted by Meteoro with its corporate offices in Oklahoma. Six Flags announced the introduction of a similar ride at one of it’s theme parks. Meteoro filed suit in the Northern District of New York and Six Flags sought to transfer to the Western District of Oklahoma, the Central District of California, or the Southern District of New York.

Issue.

Whether a federal district court can transfer a suit to another district court with jurisdiction where the suit may have been filed originally?

Held.

Yes. The case will be transferred to the Western District of Oklahoma. It has been undetermined whether the jury actually needs to see the rollercoaster located in California. The Northern District of New York is an improper venue and Six Flags’ headquarters and most of its witnesses are within Oklahoma.

Discussion.

28 U.S.C. §1404(a), permits a federal district court to transfer a suit to another district court with jurisdiction where the suit may have been filed originally. The most important factor in determining when to transfer venue is witness convenience.