Maria Morado, et al. v. Archer-Daniels Midland Co., et al.

CourtDistrict Court, W.D. Oklahoma
DecidedOctober 15, 2025
Docket5:25-cv-01213
StatusUnknown

This text of Maria Morado, et al. v. Archer-Daniels Midland Co., et al. (Maria Morado, et al. v. Archer-Daniels Midland Co., et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maria Morado, et al. v. Archer-Daniels Midland Co., et al., (W.D. Okla. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

MARIA MORADO, ET AL.,

Plaintiffs,

v. No. 4:25-cv-01017-P

ARCHER-DANIELS MIDLAND CO., ET AL.,

Defendants. OPINION & ORDER Before the Court is the Motion to Dismiss or in the Alternative Transfer Venue. ECF No. 11. For the reasons below, the motion is GRANTED IN PART and the case is hereby TRANFERRED to the United States District Court for the Western District of Oklahoma. BACKGROUND This case arose from the tragic death of Juan Morado, who passed away in Hooker, Oklahoma on October 5, 2023. ECF No. 1, Ex. 1. Morado, while working for his employer—Defendant Kyler Erwin Construction (KEC)—at a facility owned and operated by Defendant Archer-Daniels Midland Company (ADM), passed away while on the job. ECF No. 1, Ex. 1. Morado, while stationed in the basket of a lift device, used a Hydrovac Hose to vacuum the inside of a rail car. ECF No. 1, Ex. 1. While attempting to unclog the Hydrovac, the vacuum broke. ECF No. 1, Ex. 1. It killed him by launching him off the rail car. ECF No. 1, Ex. 1. Plaintiffs, Morado’s widow and children, brought suit against Defendants KEC and ADM in Texas state court in Wise County, Texas. ECF No. 1. at 1. ADM then removed to the Northern District of Texas, Fort Worth Division. ECF No. 1. ADM asserts that the Court has diversity jurisdiction because complete diversity exists between ADM, a Delaware corporation with its principal place of business in Illinois, and the Morados, residents of Texas. ECF No. 1. ADM argues that KEC’s citizenship in Texas should be ignored because Plaintiff improperly joined it to the action. ECF No. 1. ADM subsequently filed the Motion to Dismiss for lack of personal jurisdiction, or in the Alternative to Transfer Venue currently before the Court. ECF No. 11. The Court next ordered expedited briefing on that motion. ECF No. 13. Having considered the briefs, the Court finds it sufficient to address only the motion to transfer venue. LEGAL STANDARD A. Motion to Transfer Venue Federal venue rules permit a district court to transfer any civil action to any other district or division where it might have been brought “for the convenience of parties and witnesses [or] in the interest of justice.” 28 U.S.C. § 1404(a). In determining whether to transfer a civil action under § 1404, courts consider both private and public factors in deciding if convenience or justice warrant transferring the action to that district. See 28 U.S.C. § 1494; see also In re Volkswagen of Am., Inc., 545 F.3d 304, 315 (5th Cir. 2008) (en banc) (citing Piper Aircraft Co. v. Reyna, 454 U.S. 235, 241 n.6 (1981)). A plaintiff’s original choice of forum is entitled to some deference, which dictates that the moving party must show “that the transferee venue is clearly more convenient.” Id. But, while a plaintiff’s choice of forum “should be respected” unless “the transferee venue is clearly more convenient,” plaintiff’s “choice of forum … is not an independent factor within … the § 1404(a) analysis.” Id. at 314 n.10, 315. Rather, “a plaintiff’s choice of venue is to be treated as a burden of proof question.” Id. at 314 n.10 (cleaned up). ANALYSIS A. Appropriate Order of Jurisdictional Questions In assessing the motions before it, the Court must first determine if caselaw requires it to address the motions in a particular order, then must resolve the motions as appropriate. Without jurisdiction, a court cannot proceed at all in any case. N.A.A.C.P. v. City of Kyle, Tex., 626 F.3d 233, 237 (5th Cir. 2010). Generally, a court must resolve any dispute to its jurisdiction before proceeding further with a matter. Id.; see also Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83, 94 (1998). Though this obligation to resolve jurisdictional issues once carried a clear order of operations,1 there is no longer a step-by-step approach to jurisdictional questions. Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583–88 (1999). The Court held that there may be any number of jurisdictional questions before a court with varying levels of complexity that a judge may properly within his discretion turn directly to the issue offering the most expedient resolution. Id. at 587–88. This discretion permits courts to bypass subject-matter or personal jurisdiction questions “when considerations of convenience, fairness, and judicial economy so warrant.” Id.; see Sinochem Int’l Co. v. Malaysia Int’l Shipping Corp., 549 U.S. 422, 432 (2007). In its contemplation of a jurisdictional inquiry, a court may choose to look at an issue of venue and its included factors to ensure that the pursuit of justice in a case is properly efficient. Sinochem, 549 U.S. at 35. Indeed, where a case is filed in the wrong forum, courts are authorized to take “the less burdensome course” and transfer the case, rather than address subject-matter jurisdiction. Id. In the instant case, the Court is faced with concerns about personal jurisdiction, subject matter jurisdiction, and venue—matters that must be addressed before proceeding to the merits. Courts enjoy broad

1 In Leroy v. Great Western United Corporation, the Supreme Court asserted that personal jurisdiction is decided before venue, and subject matter jurisdiction is preliminary to both. 443 U.S. 173 (1979). This rule has since been replaced by the approach adopted in Ruhrgas AG v. Marathon Oil Company et al. 526 U.S. 574, 583–88 (1999). discretion to resolve matters that deny parties an audience on the merits—including venue. Sinochem, 549 U.S. at 435. As such, the Court in its discretion may resolve the jurisdictional questions before it in the order it deems most expedient. Accordingly the Court addresses the motion to transfer venue. B. Motion to Transfer Section 1404(a) provides that, “[f]or the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought or to any district or division to which all parties have consented.” When considering the transfer of venue, the Fifth Circuit has identified eight factors, four private and four public, to consider.” The private interest factors are: (1) the relative ease of access to source 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 …. The public interest factors are: (1) the administrative difficulties flowing from court congestion; (2) the local interest in having localized interests decided at 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 or in the application of foreign law. In re Volkswagen of Am., Inc., 545 F.3d 304

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Related

Leroy v. Great Western United Corp.
443 U.S. 173 (Supreme Court, 1979)
Piper Aircraft Co. v. Reyno
454 U.S. 235 (Supreme Court, 1982)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
Steel Co. v. Citizens for a Better Environment
523 U.S. 83 (Supreme Court, 1998)
In re Volkswagen of America, Inc.
545 F.3d 304 (Fifth Circuit, 2008)

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Bluebook (online)
Maria Morado, et al. v. Archer-Daniels Midland Co., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/maria-morado-et-al-v-archer-daniels-midland-co-et-al-okwd-2025.