Roethlisberger v. McNulty

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Justia Opinion Summary

Respondent Andrea McNulty filed a complaint in a district court located in Washoe County, alleging tort claims against appellant Ben Roethlisberger and eight other defendants. The events on which the allegations were based occurred in Douglas County. Roethlisberger was a resident of Pennsylvania. Roethlisberger filed a motion to change venue to Douglas County, arguing that venue was improper in Washoe County because no defendant resided there. The district court denied the motion. On appeal, Roethlisberger asserted that (1) because a codefendant actually resided in Douglas County, and because no other defendant resided in Washoe County, venue was improper there, and (2) the district court abused its discretion in concluding that convenience and the ends of justice did not require removal to Douglas County. The Supreme Court affirmed, holding (1) as venue was not improper as to appellant, he lacked standing to challenge venue based on his codefendant's place of residence; and (2) the district court did not abuse its discretion in refusing to change the place of trial.

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