Linda Jenkins v. Peter Pan Bus Line

CourtDistrict Court, E.D. Pennsylvania
DecidedFebruary 5, 2026
Docket2:25-cv-06642
StatusUnknown

This text of Linda Jenkins v. Peter Pan Bus Line (Linda Jenkins v. Peter Pan Bus Line) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Linda Jenkins v. Peter Pan Bus Line, (E.D. Pa. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

LINDA JENKINS, : CIVIL ACTION Plaintiff, : : v. : : PETER PAN BUS LINE, : No. 25-cv-6642 Defendant. :

MEMORANDUM KENNEY, J. February 5, 2026 Defendant moves to transfer this case to the U.S. District Court for the District of Massachusetts, pursuant to 28 U.S.C. § 1404(a). See ECF No. 12 at 1. Previously, Defendant also moved for a more definite statement, see id., but it has withdrawn that portion of the Motion, ECF No. 16 at 1. For the reasons set forth below, the Motion to Transfer (ECF No. 12) will be DENIED. I. DISCUSSION Under 28 U.S.C. § 1404(a), “a district court may transfer [a] civil action to any other district or division where it might have been brought” or “to which all parties have consented” for “the convenience of parties and witnesses” and “in the interest of justice.” In deciding a motion to transfer under § 1404(a), unless all parties have consented to another venue, a court must first determine whether venue would be proper in the district to which the case would be transferred. See Atl. Marine Constr. Co. v. U.S. Dist. Ct. for W.D. Tex., 571 U.S. 49, 59 (2013). The court must then weigh the private interests of the parties and the interests of the public to decide if transfer is warranted. See id. at 62–63. In weighing these factors, “[t]he decision to transfer is in the court’s discretion, but a transfer is not to be liberally granted.” Shutte v. Armco Steel Corp., 431 F.2d 22, 25 (3d Cir. 1970) (citation omitted). Plaintiff does not consent to transfer, so the Court first determines whether venue would lie in the District of Massachusetts. Venue lies, among other circumstances, in any “district in which any defendant resides, if all defendants are residents of the State in which the district is located.” 28 U.S.C. § 1391(b)(1). For the purposes of venue, a corporate defendant is a resident of “any judicial district in which such defendant is subject to the court’s personal jurisdiction.” Id.

§ 1391(c)(2). And there is general personal jurisdiction over a corporation in its principal place of business and place of incorporation. See BNSF Ry. v. Tyrrell, 581 U.S. 402, 413 (2017). Here, venue lies in the District of Massachusetts because the sole Defendant in this case is a Massachusetts resident. See 28 U.S.C. § 1391(b)(1). Defendant represents that it is a citizen of Massachusetts, see ECF No. 9 at 1, with a principal place of business in Springfield, Massachusetts, see ECF No. 12 at 14. The District of Massachusetts therefore has general personal jurisdiction over Defendant, rendering Defendant a resident of Massachusetts for venue purposes. See 28 U.S.C. § 1391(c)(2). Defendant therefore satisfies the threshold requirement to transfer the case to the District of Massachusetts.

The Court turns next to balancing the parties’ and public’s interests in transferring the case. See Atl. Marine Constr. Co., 571 U.S. at 62–63. The parties’ interests weigh modestly against transfer. To weigh the parties’ interests, courts may look to the location in which the claims arose, the convenience to witnesses and litigants, the location of relevant records, the plaintiff’s original choice of forum, the defendant’s preferred forum, and any other factors that would streamline trying the case. In re Howmedica Osteonics Corp., 867 F.3d 390, 402 (3d Cir. 2017). Here, Plaintiff brings claims arising from the alleged unsafe operation of a bus on which she was a passenger. See ECF No. 1-3 at 6. The location in which these claims arose is either in the Eastern District of Pennsylvania or substantially closer to this District than to the District of Massachusetts. Plaintiff boarded the bus in Philadelphia, where the bus would presumably have been inspected. See ECF No. 17 at 1. Likewise, the accident occurred “roughly twenty to twenty-five minutes after the bus departed” from Philadelphia. Id. at 2. Thus, any mechanical issues or road conditions relevant to the accident arose in or near Philadelphia. And no conduct directly precipitating the bus accident appears to have occurred in or near Massachusetts.

Convenience to witnesses is neutral because this District is more convenient for some witnesses but less convenient for others. For instance, Plaintiff made an incident report in person to a Peter Pan employee upon arriving in New York City. See id. Assuming that employee resides near New York City, this District would be more convenient. Likewise, any mechanical inspections of the bus in Philadelphia would have presumably been conducted by employees in or near Philadelphia. On the other hand, the Peter Pan employee who investigated Plaintiff’s claim is located in Massachusetts. Id. at 4. Likewise, Plaintiff received all medical treatment in Rhode Island, which is closer to the District of Massachusetts. See id. at 2. However, the location of Plaintiff’s medical treatment is most relevant to where her records are located, and the location of

records is entitled to little weight given the widespread practice of electronic record-keeping. See Civello v. Equinix, Inc., No. 24-CV-08803, 2025 WL 660247, at *3 (N.D. Cal. Feb. 28, 2025). Lastly, the choice of forum and convenience to litigants is neutral or, at most, slightly favors transfer. Plaintiff’s original choice of forum is in the Eastern District of Pennsylvania. Because this District “is not [her] home forum,” the deference given to this factor is lessened but is not eliminated. See Sinochem Int’l Co. v. Malay. Int’l Shipping Corp., 549 U.S. 422, 430 (2007). The Defendant’s choice of forum is the District of Massachusetts, and Massachusetts is also more convenient to Defendant, whose principal place of business is located there. See ECF No. 12 at 14. However, a defendant’s choice of forum is afforded “considerably less weight than the plaintiff’s.” See N. Am. Commc’ns, Inc. v. Eclipse Acqui Inc., No. CV 3:17-167, 2018 WL 651795, at *6 n.10 (W.D. Pa. Jan. 31, 2018) (internal quotation marks and citation omitted). And the Court takes notice that Defendant holds itself out as having locations across the East Coast, including near the Eastern District of Pennsylvania. Locations, https://peterpanbus.com/locations/ [https://perma.cc/ 33P2-MA63] (last visited Feb. 4, 2026). All told, and bearing in mind that virtually no aspects of

this accident arose near the District of Massachusetts, the private interest factors weigh modestly against transfer. The public interest factors weigh modestly against transfer, too. To evaluate the public’s interests, courts may consider factors such as the relative congestion of the transferor and transferee districts, the familiarity of the districts with the applicable state law in a diversity case, “the public policies of the fora,” the enforceability of the judgment, and “the local interest in deciding local controversies at home.” In re Howmedica Osteonics Corp., 867 F.3d at 402 (citation omitted). Here, many of these factors are neutral.

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

Related

United States v. H & R Block, Inc.
789 F. Supp. 2d 74 (District of Columbia, 2011)
In Re Howmedica Osteonics Corp.
867 F.3d 390 (Third Circuit, 2017)
BNSF Ry. Co. v. Tyrrell
581 U.S. 402 (Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Linda Jenkins v. Peter Pan Bus Line, Counsel Stack Legal Research, https://law.counselstack.com/opinion/linda-jenkins-v-peter-pan-bus-line-paed-2026.