Camp v. Gress
Headline: Venue ruling limits where out-of-state co‑defendants can be sued, reverses judgment against a nonresident co‑defendant and affirms judgment against resident co‑defendants in a multi‑defendant diversity suit.
Holding:
- Nonresident co‑defendants can be dismissed from suits filed outside their home district.
- Resident co‑defendants cannot use a nonresident’s venue privilege to avoid suit.
- Plaintiffs must bring diversity suits in districts of either the plaintiff or defendant.
Summary
Background
A Florida man who owned a sawmill business sued three landowners in a Virginia federal district court after they broke a contract to form a lumber company. The plaintiff relied on diversity of citizenship to bring the case in federal court. Two defendants were residents of the Virginia district where the suit was filed, but the third defendant was a North Carolina resident who said he could not be sued in that Virginia district.
Reasoning
The Court addressed whether a nonresident co‑defendant can insist on being sued only in his own home district. It read Section 51 of the Judicial Code together with earlier cases and related provisions. The Justices concluded that the statute gives a personal privilege to a defendant who does not live in the district where the suit was brought, so the North Carolina defendant’s plea to the venue should have been sustained. The Court reversed the judgment as to that nonresident. At the same time, the Court held that the two Virginia resident co‑defendants could not use the nonresident’s privilege to escape the suit, and it affirmed the judgment against them.
Real world impact
The decision means out‑of‑state co‑defendants can successfully object to being sued in a district where they do not live, while co‑defendants who live in the forum cannot claim that same exemption. The Court also upheld the damages award rules applied below, allowing the plaintiff to recover the loss caused by the breach without requiring a corporate accounting first. This resolves venue and damages questions in this case and guides similar multi‑defendant diversity disputes.
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