Langley v. NetJets Aviation Inc

CourtDistrict Court, N.D. Texas
DecidedFebruary 18, 2025
Docket3:23-cv-02300
StatusUnknown

This text of Langley v. NetJets Aviation Inc (Langley v. NetJets Aviation Inc) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Langley v. NetJets Aviation Inc, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

GREGORY LANGLEY, et al., § § Plaintiffs, § § v. § Civil Action No. 3:23-CV-2300-X § NETJETS AVIATION INC., § § Defendant. §

MEMORANDUM OPINION AND ORDER Having considered the underlying facts, the parties’ arguments, and the applicable caselaw, the Court finds that transfer is appropriate. The Court GRANTS LEAVE to the parties to file objections, if any, on or before fourteen days from the date of this order. If no objections are filed within fourteen days of the date of this order, the Court will transfer the case to the United States District Court for the Southern District of Ohio, Eastern Division. If the parties determine before the fourteen-day window that they will not file objections, the Court ORDERS the parties to file a joint status report noting that they waive any objections to transfer. I. Factual Background Defendant NetJets Aviation Inc. is a private business jet charter and aircraft management company. The plaintiffs were pilots employed by NetJets to fly its private charter jets. In December 2022, a federal omnibus spending bill passed, which allowed large fractional operators and charter providers to set a voluntary 70- year-old age limit for pilots. NetJets adopted a mandatory retirement age of 70 for its pilots, effective January 10, 2024. The plaintiffs filed this lawsuit and a motion for a preliminary injunction seeking an order to halt implementation of that policy, which this Court denied. Now, NetJets seeks to dismiss this action for, among other

things, want of proper venue. II. Legal Standard Title 28, section 1404 of the United States Code authorizes a district court to sua sponte “transfer any civil action to any other district or division where it might have been brought” for “the convenience of parties and witnesses, in the interest of justice.”1 This statute codifies “the doctrine of forum non conveniens for the subset of

cases in which the transferee forum is within the federal court system.”2 “In cases where there is no forum-selection clause, district courts ‘must evaluate both the convenience of the parties and various public-interest considerations.’”3 District courts analyze section 1404(a) transfers with private- and public-interest factors: Factors relating to the parties’ private interests include relative ease of access to sources of proof; availability of compulsory process for attendance of unwilling, and the cost of obtaining attendance of willing, witnesses; possibility of view of premises, if view would be appropriate to the action; and all other practical problems that make trial of a case easy, expeditious and inexpensive. Public-interest factors may include the administrative difficulties flowing from court congestion; the local interest in having localized controversies decided at home; and the interest in having the trial of a diversity case in a forum that is at home

1 28 U.S.C. § 1404(a); see also Mills v. Beech Aircraft Corp., Inc., 886 F.2d 758, 761 (5th Cir. 1989) (“Such transfers may be made sua sponte.”). 2 Atl. Marine Constr. Co. v. U.S. Dist. Court for W. D. of Tex., 571 U.S. 49, 60 (2013). 3 DSA Promotions, LLC v. Vonage Am., Inc., 2018 WL 1071278, at *2 (N.D. Tex. Feb. 27, 2018) (Fitzwater, J.) (quoting Atl. Marine, 571 U.S. at 62). with the law. The Court must also give some weight to the plaintiffs’ choice of forum.4 “Decisions to effect 1404 transfers are committed to the sound discretion of the transferring judge, and review of a transfer is limited to abuse of that discretion.”5 III. Legal Analysis A. Private Factors As for the relative ease of access to sources of proof, in an age discrimination

case, the sources of proof won’t be in Texas—they’ll likely be in Ohio, where NetJets’ principal place of business is.6 Witnesses are similar. The plaintiffs provide no indication that any witnesses are in Texas whatsoever. Therefore, compelling out-of- state witnesses would certainly be both burdensome and costly. Further, no property is in dispute in this action, so that factor is irrelevant. As for the other private factors, the plaintiffs confirm that the principal place of business is NetJets’ office in Ohio.7 The plaintiffs never dispute that none of them

are Texans. Also, this litigation is about a change in NetJets’ corporate policy and whether it is discriminatory. Absent some meaningful Texas connection, a challenge to the corporate policy of a non-Texas company by non-Texans should be brought in not-Texas. For their part, the plaintiffs point to the fact that NetJets has a training program, safety courses, and recruiting events in Texas, contracts with Texas companies, advertises in Texas, maintains a facility at Love Field, flies out of Dallas–

4 Atl. Marine, 571 U.S. at 62, n. 6 (cleaned up). 5 Jarvis Christian Coll. V. Exxon Corp., 845 F.2d 523, 528 (5th Cir 1988). 6 Doc. 49 at 2. 7 Doc. 49 at 2. Fort Worth Airport, and has Texan customers (referred to as “Owners” because they own fractions of the planes).8 But none of these represent the sort of connection to the Northern District that indicates witnesses or sources of proof for this dispute are

in the Northern District.9 Additionally, the Court takes a realistic approach to transfer here. After a preliminary review of the pleadings and arguments, it appears this Court likely lacks personal jurisdiction over NetJets. But to determine this conclusively—because of the plaintiffs’ woefully inadequate briefing—the Court would need to order jurisdictional discovery, hold a hearing, and decide that preliminary question before

jumping into the merits of the parties’ (largely legal) arguments. That’s a lot of time and money to expend in a case that is already over a year old to answer the question of whether or not personal jurisdiction exists. Rather than burden the parties with this potentially inconsequential rigamarole, it’s better for the judiciary and the parties to get this case back on track and moving forward. Finally, there’s a question of justice to the parties. The plaintiffs have already filed three complaints,10 and the parties have fully briefed two sets of motions to

8 Doc. 37 at 8–9. 9 This also bears on the Court’s reasoning in the “public factors” section because the Court is supposed to look to the locale of the “the events—not the parties.” In re Clarke, 94 F.4th 502, 511 (5th Cir. 2024). None of those allegations concern where the events leading to this lawsuit took place. Indeed, all they reflect is that NetJets has some connections to Texas—not that this lawsuit has connections to Texas. 10 Docs. 1, 18, 49. dismiss.11 Subjecting them to more wheel-spinning here is not justice—it’s delay. Accordingly, the private interest factors weigh in favor of transfer. B. Public Factors

While the Court does not think court congestion will be a problem, there is a significant interest in having local cases decided at home. “Considerations such as the location of the injury, witnesses, and the plaintiff’s residence, are useful proxies for determining what local interests exist in each venue.”12 The plaintiffs never make clear where any of their injuries occurred. That is, they never say that they were injured in Texas, employed out of the Texas office,

terminated in Texas, or that they live in Texas such that the effects of their purportedly wrongful terminations were felt in Texas. They plead no meaningful connection between their purported injury and Texas.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Langley v. NetJets Aviation Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/langley-v-netjets-aviation-inc-txnd-2025.