Smith v. Colonial Penn Ins. Co.
United States District Court for the Southern District of Texas
943 F. Supp. 782 (S.D. Tex. 1996)
Relevant factsFree
Smith (plaintiff) sued Colonial Penn (defendant) for breach of an insurance contract in the Galveston Division; Colonial Penn moved under 28 U.S.C. § 1404(a) to transfer to the Houston Division, arguing Galveston's lack of an airport made it an inconvenient forum.
IssueFree
Whether a federal district court judge must transfer a case to a different venue if the city in which the courthouse sits has no airport.