Erickson v. Exxon Mobil Corporation

CourtDistrict Court, S.D. Texas
DecidedApril 8, 2025
Docket3:24-cv-00363
StatusUnknown

This text of Erickson v. Exxon Mobil Corporation (Erickson v. Exxon Mobil Corporation) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Erickson v. Exxon Mobil Corporation, (S.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT April 08, 2025 Nathan Ochsner, Clerk FOR THE SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION

══════════ No. 3:24-cv-363 ══════════

PAUL ERICKSON, THOMAS CLIFT, AND CRAIG NEUMAN, Plaintiffs,

v.

EXXON MOBIL CORPORATION, Defendant.

══════════════════════════════════════════ MEMORANDUM OPINION AND ORDER ══════════════════════════════════════════ JEFFREY VINCENT BROWN, UNITED STATES DISTRICT JUDGE. Before the court is the defendant’s motion to transfer venue to Houston. Dkt. 11. The court will deny the motion. I. Background Exxon Mobil Corporation employs Paul Erickson, Thomas Clift, and Craig Neuman as pilots. Dkt. 1 §§ 37–39. When Exxon mandated COVID-19 vaccination for its employees in December 2021, Erickson, Clift, and Neuman applied for religious accommodations. Id. §§ 48, 61–62, 91–92, 111–12. All three continued working unvaccinated for six months without issue. Id. § 53. That August, Exxon granted their requested accommodations but restricted them to domestic flights. Id. §§ 54, 69–70, 99–100, 120. This 1/10 change affected their titles, performance reviews, and benefits until Exxon withdrew the vaccine mandate in November. Id. §§ 7–9, 31.

Two years later, after receiving right-to-sue notices from the EEOC, Erickson, Clift, and Neuman brought religious-discrimination and retaliation claims under Title VII against Exxon. Id. §§ 84, 107, 130, 179– 227. ExxonMobil has moved to transfer venue to Houston under 28 U.S.C.

§ 1404. Dkt. 11. II. Legal Standard A district court “for the convenience of parties and witnesses” and “in

the interest of justice . . . may transfer any civil action to any other district or division where it might have been brought.” 28 U.S. § 1404(a). Courts weigh several public- and private-interest factors to determine whether a transfer under § 1404 is warranted. In re Volkswagen AG, 371 F.3d 201, 203 (5th Cir.

2004) (Volkswagen I). The private concerns include: (1) the relative ease of access to sources of proof; (2) the availability of compulsory process to secure the attendance of witnesses; (3) the cost of attendance for willing witnesses; and (4) all other practical problems that make trial of a case easy, expeditious and inexpensive. Id.

The public concerns include: (1) the administrative difficulties flowing from court congestion; (2) the local interest in having localized interests decided at 2/10 home; (3) the familiarity of the forum with the law that will govern the case; and (4) the avoidance of unnecessary problems of conflict of laws of the application of foreign law. Id.

A “[p]laintiff’s privilege to choose, or not to be ousted from, his chosen forum is highly esteemed.” Time, Inc. v. Manning, 366 F.2d 690, 698 (5th Cir. 1966) (citation omitted). For this reason, the movant bears the burden of showing transfer is necessary. Id. “Decisions to effect a [section] 1404 transfer are committed to the sound discretion of the transferring judge.” Jarvis Christian Coll. v. Exxon Corp., 845 F.2d 523, 528 (5th Cir. 1988). III. Analysis

Exxon argues venue should lie in Houston for the convenience of the parties and witnesses, while the plaintiffs maintain their forum choice of Galveston is due deference. Dkts. 11, 18. But the parties agree, and the court concurs, that this suit could have been properly filed in Houston. Dkts. 11 at

11–12; 18 at 8 n.1; see Hebert v. Wade, No. 3:13-CV-00076, 2013 WL 5551037, at *3 (S.D. Tex. Oct. 7, 2013) (“The venue statute, 28 U.S.C. § 1391, is based on districts, not divisions. If venue is proper in Galveston, it is also proper in Houston.”). Accordingly, the court will consider the private and

public concerns in turn. See Buc-ee’s, Ltd. v. Bucks, Inc., 262 F. Supp. 3d 453,

3/10 462 (S.D. Tex. 2017) (stating the court balances the factors if it finds the case could have been originally filed in the transferee district).

A. Private-Interest Factors Exxon asserts two private-interest factors favor Houston—ease of access to proof and cost of witness attendance—and the remaining two are neutral. Dkt. 11 at 12–15. The plaintiffs concede the cost of witness

attendance “might slightly” favor Houston and argue the remaining factors are neutral. Dkt. 18 at 8. The access-to-proof factor “focuses on the location of the relevant documents and physical evidence relative to the transferee and transferor

venues.” Qualls v. Prewett Enters., Inc., 594 F. Supp. 3d 813, 823 (S.D. Tex. 2022) (quotations and citation omitted). Exxon argues the physical evidence related to the plaintiffs’ ongoing employment is at George Bush Intercontinental Airport (“IAH”) or managed from Exxon’s campus in

Spring. Dkt. 11 at 12. Indeed, all the employment actions at issue took place in the Houston Division. Id. The plaintiffs emphasize all this evidence is digital, but “technological advancements neither lighten the weight of this

factor nor render it ‘superfluous.’” Dkt. 18 at 9–10; Qualls, 594 F. Supp. 3d at 823 (quoting In re Volkswagen of Am., Inc., 545 F.3d 304, 316 (5th Cir.

4/10 2008) (Volkswagen II)). That files can be sent electronically does not preclude the location of the files weighing in favor of transfer. Qualls, 594 F.

Supp. 3d at 823; see also Sandbox Logistics LLC v. Grit Energy Sols. LLC, No. 3:16-CV-12, 2016 WL 4400312, at *3 (S.D. Tex. Aug. 17, 2016) (electronically stored documentary evidence “does not negate the significance of having trial closer to where [the plaintiffs’] physical

documents are located, because the critical inquiry is relative ease of access, not absolute ease of access”) (cleaned up and citation omitted). Accordingly, the court finds the relative ease of access to proof favors Houston.

Next, the cost of attendance for willing witnesses. The court considers the convenience of party and non-party witnesses, although the latter is more important. Hillestad v. LLOG Expl. Co., LLC, No. 3:17-CV-00341, 2018 WL 4938708, at *4 (S.D. Tex. Sept. 20, 2018), report and recommendation

adopted, No. 3:17-CV-00341, 2018 WL 4931783 (S.D. Tex. Oct. 11, 2018). The Fifth Circuit gives substantial weight to this factor when witnesses must travel over 100 miles to attend trial. Volkswagen I, 371 F.3d at 204–05. Exxon identifies four primary witnesses—Jean Claude Francois

Jaubert, Charles Cone, Geoffrey Thomas Cirigliano, and Greg Tupper—who reside outside the Galveston Division. Dkt. 11 at 9. Jaubert is retired, and

5/10 Cone, Cirigliano, and Tupper are current Exxon employees. Id. Cone and Cirigliano live in Spring, only 75 miles from Galveston. Id.; see Volkswagen

I, 371 F.3d at 204–05 (attaching greater importance to witnesses traveling more than 100 miles). Houston may be more convenient for them, but there are worse things than driving an extra hour—especially when your journey ends with the Galveston Bay “mirroring and magnifying the bright rays of

the sun and clouds.” Hillestad, 2018 WL 4938708, at *5 (“[A]ny inconvenience suffered in having to drive to Galveston may likely be offset by the peacefulness of the ride and the scenic beauty of the sunny isle.”

(citation omitted)). Tupper and Jaubert, however, have a longer trek.

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