Plaintiff, a resident of California, was injured on defendant corporation's premises in Nevada. Being unable to serve defendant in California, plaintiff started a negligence action in the Federal District Court in Nevada and then moved for a change of venue to the proper Federal District Court in California under section 1404(a) of the Judicial Code. The Federal District Court of Nevada overruled plaintiff's motion. On appeal, held, affirmed. The requirement under 1404(a) that the action be transferred to any district "where it might have been brought" precludes transfer to a forum where the defendant was not amenable to process. Shapiro v. Bonanza Hotel Co., (9th Cir. 1950) 185 F. (2d) 777.
David F. Ulmer S. Ed.,
FEDERAL PROCEDURE-CHANGE OF VENUE ON MOTION OF THE PLAINTIFF,
Mich. L. Rev.
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