Platt v. Minnesota Mining & Manufacturing Co.

Background

A grand jury in Danville, Illinois, indicted a Minnesota-based company on antitrust charges involving several products. The company asked the trial judge to move the criminal trial from the Eastern District of Illinois to Minnesota. The judge denied the request after weighing convenience, expense, speed of trial, and noting it might be harder for the Government to get a fair jury in Minnesota. The company petitioned the Court of Appeals, which ordered the transfer by writ of mandamus.

Reasoning

The Supreme Court reviewed whether the Court of Appeals should have overruled the trial judge by conducting its own fresh review and ordering the transfer. The Court said the appeals court went too far: extraordinary writs like mandamus are reserved for rare cases, and an appellate court should not substitute its own weighing of discretionary factors. The Court listed the practical factors to consider (location of defendant, witnesses, events, records, business disruption, expense, counsel, accessibility, docket condition, and other special elements) and told the trial judge to reconsider the motion without relying on speculation about jury fairness in Minnesota.

Real world impact

The case is sent back to the trial judge to reweigh the specified practical factors. Appeals courts may not simply substitute their own factual findings to order transfers. The decision also makes clear that a defendant’s home office does not automatically require transfer and that guesses about an impartial jury in another district should not control the venue decision.

Dissents or concurrances

Justice Harlan agreed and emphasized that speculation a district cannot supply an impartial jury is out of bounds, and that an appeals court should not make a fresh, from-scratch transfer determination.