John David Miley, III and Dr. Steven Richard Smith v. Hatteras Funds, L.P., et al.

Summary

The U.S. District Court for the District of Delaware denied Defendants’ motion under 28 U.S.C. § 1404(a) to transfer the action to the Eastern District of North Carolina. Applying the twelve Jumara factors, the court found that Plaintiffs’ choice of forum was entitled to paramount consideration and that the factors did not strongly favor transfer. The action concerns alleged tortious interference and breach of fiduciary duty arising from an investment-fund liquidation transaction involving Beneficient securities.

Holdings

1. Under binding Third Circuit precedent, a plaintiff's choice of a proper forum is a paramount consideration in a § 1404(a) transfer analysis and should not be discounted merely because the plaintiff resides elsewhere or the underlying events occurred elsewhere.
2. Defendants failed to establish that the Jumara factors weighed strongly in favor of transfer; the motion to transfer was therefore denied.

Questions Presented

1. Whether the private and public interests identified in Jumara and 28 U.S.C. § 1404(a) strongly favored transferring the action from the District of Delaware to the Eastern District of North Carolina.
2. Whether Plaintiffs' choice of Delaware as the forum was entitled to paramount consideration despite Plaintiffs' Indiana residence and the lack of an apparent factual connection to Delaware.

Disposition

denied