Hoffman v. Blaski Case Brief

Why is the case important?

Plaintiffs, citizens of Illinois, brought suit for patent infringement against a Texas corporation in the District Court of Texas. Defendant moved to transfer the case to the District Court of Illinois pursuant to 28 U.S.C. Section: 1404(a), and the case was so transferred. Plaintiff appealed, arguing that the District Court abused its discretion in transferring the case.

Facts of the case

Question

Does the federal statute 28 U.S.C. Section: 1404(a) that states the defendant may remove the action to any district where it might have been brought refers to jurisdictions where the action could have been brought at the time of filing?

Answer

Yes. Affirmed. The power of the District Court to transfer an action under the statute is limited to places where the plaintiff could have brought the action at the time it was filed, regardless of whether the defendant consents to the transfer. By broadening the meaning of the statute’s words in the manner requested, the defendants would be able to transfer venue to anywhere where subject matter jurisdiction exists, and the plaintiff would not be able to do the same without the defendant’s consent. There is no evidence that the drafters intended this result.

Conclusion

“Based upon the statutory language and legislative history, the phrase “”where it might have been brought”” in § 1404(a) could not be interpreted to mean “”where the case could be brought after the suit was initiated and with defendants’ consent.”” The district courts’ power to transfer a case under § 1404(a) did not depend on whether the third parties consented to the transferee district or waived venue and personal jurisdiction defenses, but rather it depended on respondents’ ability to initiate the suits in the transferee districts.”

  • Case Brief: 1960
  • Petitioner: Hoffman
  • Respondent: Blaski
  • Decided by: Warren Court

Citation: 363 US 335 (1960)
Argued: Apr 19 – 20, 1960
Decided: Jun 13, 1960