Tuesday, March 10, 2015

Hoffman v. Blaski case brief summary

Hoffman v. Blaski case brief
1960 SCOTUS

Posture: Patent case brought by plaintiff in district court in Texas. Defendants asked for a transfer of venue under 1404 (a) to Illinois District court for convenience purposes. District Court of Texas granted it; Plaintiff filed for mandamus relief in Fifth circuit directing order to be reversed because plaintiff was not able to bring a suit in Illinois originally which is what 1404 (a) says. District court direct relief and gave it to Hoffman. Plaintiff moved for an order remanding action on Texas’ lack of power to make transfer order. Hoffman, with misgivings, denies motion and plaintiff asks for mandamus relief again. Appeals granted motion and SCOTUS affirms.

Issue: Does a District Court have the power to transfer the action which was properly brought, on a motion of the defendant, to a district in which plaintiff did not have a right to bring case?

Facts: The posture is pretty much the facts. 1404 (a) allows for transfer of venue under words “where it might have been brought” which is related to where plaintiff could have brought action.

Reasoning: Whittaker: Affirmed the mandamus relief. Think that it does not make sense to allow defendant to be able to move the case to any District in the country when plaintiff would not even be allowed to bring suit in that state. A defendant can always, in that case, waive venue and jurisdiction and find that he/she can bring the case in any state in the country. The slippery slope argument shows that defendants reasoning is not sound. Also, granting 1404 (a) every time would discriminate against plaintiff who does not have this power to bring suit anywhere.

Frankfurter dissent: Says that the court’s reasoning that a transfer could always be made is false. The statute requires convenience and justice to be proved necessary elements before having case transferred anywhere. Also said that forum non conveniens allows for defendants to move or dismiss case even without plaintiffs consent; defendants have the most power there. Dissent says that that doctrine is still very broad, narrowing this will make the other doctrine broader.

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