Goldlawr, Inc. v. Heiman

Summary

The Supreme Court held that 28 U.S.C. § 1406(a) authorizes a federal district court to transfer a case filed in an improper venue even when the transferring court lacks personal jurisdiction over the defendants. The Court reasoned that the statute is intended to prevent plaintiffs from losing claims because of venue-related mistakes and that transfer may serve the interest of justice. The judgment of the Second Circuit was reversed as to the corporate defendants; the writ was dismissed as to the individual defendant Marcus Heiman.

Holdings

1. A district court may transfer a case under § 1406(a) when venue is wrong even if the transferring court lacks personal jurisdiction over the defendants, provided transfer is in the interest of justice and the case could have been brought in the transferee district.
2. The writ was dismissed as to Marcus Heiman because the lower courts relied on a second independent ground for dismissal that was not included in the petition for certiorari.

Questions Presented

1. Whether a federal district court may transfer an action under 28 U.S.C. § 1406(a) when venue is improper and the transferring court lacks personal jurisdiction over the defendants.
2. Whether the Supreme Court should disturb the dismissal as to individual defendant Marcus Heiman when the lower courts also relied on an independent ground that was not presented for certiorari.

Disposition

reversed