Automated Summary
Key Facts
The case was transferred from the Northern District of Texas to the Eastern District of Texas, Sherman Division, due to improper venue. The court conditionally dismissed the claims for lack of subject-matter jurisdiction because the plaintiff pleaded an indeterminate amount of damages, requiring her to replead within 14 days.
Issues
- The case was transferred from the Northern District of Texas to the Eastern District of Texas, Sherman Division, under 28 U.S.C. § 1406(a) because a substantial part of the events occurred in Collin County (Plano, Texas), which falls within the Eastern District's jurisdiction.
- Plaintiff's Rule 60(a) motion and conditional clarification requests were denied as improper. The court emphasized adherence to procedural rules and noted that pro se status does not exempt compliance with local rules, including filing separate motions for distinct requests.
- Plaintiff's claims were conditionally dismissed for lack of subject-matter jurisdiction under 28 U.S.C. § 1332 due to pleading an indeterminate amount of damages. The court allowed 14 days to replead with a specific amount in controversy to establish jurisdiction.
Holdings
- The court conditionally dismissed Plaintiff's claims for lack of subject-matter jurisdiction under 28 U.S.C. § 1332 due to pleading an indeterminate amount of damages, allowing 14 days to replead the complaint. The dismissal is without prejudice if Plaintiff fails to cure the jurisdictional deficiency.
- The court transferred the case to the United States District Court for the Eastern District of Texas, Sherman Division, under 28 U.S.C. § 1406(a) because venue was improperly laid in the Northern District of Texas. The transfer was based on the events occurring in Plano, Texas (Collin County), which falls within the Eastern District's jurisdiction.
Remedies
- Case transferred to the United States District Court for the Eastern District of Texas, Sherman Division
- Conditional Dismissal with right to replead within 14 days
Legal Principles
The court applied the principle of forum non conveniens to transfer the case to the United States District Court for the Eastern District of Texas, Sherman Division, where a substantial part of the events occurred. This decision was based on 28 U.S.C. § 1391(b) and § 1406(a), emphasizing that venue must be in the district most connected to the parties or events.
Precedent Name
- Hulsey v. Texas
- Caldwell v. Palmetto State Savings Bank
- Muskrat v. United States
Cited Statute
Judiciary and Judicial Procedure Act
Judge Name
- Christine L. Stetson
- Renee Harris Toliver
- Michael J. Truncale
Passage Text
- The Court concludes that it is in the interest of justice to transfer this pro se case to the Eastern District of Texas, Sherman Division, where a substantial part of the events at issue occurred.
- On January 15, 2026, Judge Stetson found that the Court lacked jurisdiction because Plaintiff pleaded 'an indeterminate amount of damages,' which does not establish the amount in controversy required for jurisdiction under 28 U.S.C. § 1332.
- Plaintiff did not object to the Report and Recommendation. As such, the Court reviews it for clear error, and finds none.