Administrative Law

Maryland Court Sides with Columbia Lighthouse for the Blind, Transfers Employment Case to D.C.

The U.S. District Court for the District of Maryland has decided to transfer a civil employment lawsuit filed by Anthony J. Cancelosi against Columbia Lighthouse for the Blind (CLB) to the United States District Court for the District of Columbia. The court’s decision, based on a motion by CLB, hinges on factors that favor the District of Columbia as the more appropriate venue for the case.

Background of the Case

The case involves a dispute over Cancelosi’s termination from his role as President and Chief Executive Officer of CLB. Cancelosi, who is a resident of Virginia, held this position from 2005 until April 30, 2025. CLB, a non-profit organization serving the blind and visually impaired, is incorporated in and has its principal place of business in the District of Columbia.

The core of the dispute revolves around several claims: breach of contract, violations of the Maryland and District of Columbia Wage Payment and Collection Laws, and age discrimination under the District of Columbia Human Rights Act. Cancelosi alleges that CLB breached a severance agreement and failed to pay him the full amount of accrued vacation pay. He also claims he was subjected to age discrimination in connection with his termination.

The Court’s Analysis of the Transfer Motion

The court’s decision to transfer the case to the District of Columbia is based on a review of factors outlined in 28 U.S.C. § 1404(a). This section allows a district court to transfer a civil action to another district or division where the case could have been brought, considering the convenience of the parties and witnesses, and the interests of justice.

Plaintiff’s Choice of Forum

The court gave limited weight to Cancelosi’s choice of the Maryland court. Generally, a plaintiff’s choice of forum is given considerable weight, especially if the plaintiff resides in that forum. However, in this case, the court found that because Cancelosi is a resident of Virginia and the case doesn’t have significant ties to Maryland, his choice of forum was less important.

The court considered where the “substantial part of the events or omissions giving rise to the claim occurred.” While Cancelosi worked in Maryland and oversaw CLB facilities there, the court determined these activities were only “tangential” to his claims. The court emphasized that the core of the claims, including the alleged breach of contract and age discrimination, centered on events and agreements primarily based in the District of Columbia.

Convenience of Witnesses and Parties

The court found that the convenience factors slightly favored CLB. The distance between the federal courthouses in Washington, D.C., and Greenbelt, Maryland, is less than fifteen miles. The court noted that a greater number of witnesses reside in the District of Columbia than in Maryland. Additionally, the relevant documents and CLB’s corporate headquarters are located in the District of Columbia.

Interests of Justice

The court determined that the interests of justice strongly favored transferring the case. The core of Cancelosi’s claims, including the breach of contract claims and the age discrimination claim, are connected to the District of Columbia. The agreements at the center of the breach of contract claims were likely executed in the District of Columbia. Cancelosi worked primarily in the District of Columbia, and the events surrounding his termination, including the alleged discriminatory remarks, also occurred there.

The court also emphasized that the District of Columbia has a strong local interest in resolving a dispute that is so closely tied to its jurisdiction. Furthermore, the court noted that the District of Columbia is more familiar with its own laws, which apply to four of Cancelosi’s five claims.

The Ruling

Based on these considerations, the court granted CLB’s motion to transfer the case to the United States District Court for the District of Columbia.

Case Information

Case Name:
Anthony J. Cancelosi v. Columbia Lighthouse for the Blind

Court:
United States District Court for the District of Maryland

Judge:
Deborah K. Chasanow