Where a man alleged claims for religious employment discrimination arising out of his application for employment with the National-Geospatial Intelligence Agency, or NGA, the suit was transferred from Texas to Virginia, which is the location of the alleged unlawful employment practice, where the records were likely located and where the man would have been employed.
Background
Jeffrey Podell alleges employment discrimination on the basis of religion, in violation of Title VII, the Due Process Clause of the Fifth and Fourteenth Amendments, the Equal Protection Clause of the Fifth Amendment and the Religious Freedom Restoration Act. These claims arise out of defendants’ actions surrounding plaintiff’s application for employment with the NGA. Defendants have filed the motion to transfer venue to the United States District Court for the Eastern District of Virginia.
Analysis
Under 42 U.S.C. § 2000e-5(f)(3), a plaintiff may bring a Title VII action in four possible judicial districts. If a plaintiff asserts Title VII claims in a jurisdiction that does not satisfy one of the four venue requirements listed in 42 U.S.C. § 2000e-5(f)(3), venue is improper. Here plaintiff has not satisfied any of the four requirements.
Instead the Eastern District of Virginia is the appropriate location for this case under the Title VII venue provision. Though a party need only meet one subsection of the Title VII venue provision, each of the statute’s first three prongs are satisfied with respect...
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