First of Michigan Corp. v. Bramlet

Carlton and Dolores Bramlet (defendants), Florida residents, invested $62,000 in an IRA with First of Michigan Corp. through broker Michael Sobol (plaintiffs), meeting Sobol in Michigan and conducting all their investment transactions there, even though they lived in Florida. After their IRA lost more than half its value, the Bramlets initiated an NASD arbitration in Florida, alleging First of Michigan and Sobol failed to send periodic statements. First of Michigan and Sobol sued in the U.S. District Court for the Eastern District of Michigan seeking to enjoin the Florida arbitration as time-barred under NASD rules. The district court dismissed for improper venue, reasoning the 'most substantial event' -- the Bramlets initiating arbitration -- occurred in Florida, not Michigan.