Chamber of Commerce of the United States of America v. James

The federal district court for the Southern District of New York granted a motion by the New York Attorney General and the Commissioner of the New York State Department of Environmental Conservation to transfer business groups’ lawsuit challenging New York’s Climate Change Superfund Act to the Northern District of New York. The court first noted that it was undisputed that the case could have been brought in the Northern District of New York, where West Virginia and other states and business associations had filed a challenge to the law several weeks before this lawsuit was filed. The court then determined that the transfer would serve the interests of justice and convenience of the parties and witnesses. The court concluded that the interests of justice weighed heavily in favor of transfer because the “central issues” of this case and the West Virginia case were “substantially similar such that it would be inefficient and unnecessarily burdensome to litigate them in two separate courts.” The court distinguished this determination from its previous decision denying a motion to transfer the United States’ challenge to the Climate Change Superfund Act to the Northern District of New York. The court noted the difference in plaintiff types (federal government entities versus business organizations) and the presence in the United States’ case of “several legal issues” that did not overlap with the issues in this case. The court found that other factors such as the plaintiffs’ choice of forum and convenience to witnesses and parties either weighed only slightly in favor or against transfer or were neutral. The court also found that application of the “first-filed” rule would create an unrebutted presumption for transfer.

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