See Johnston v. Wilkins, 709 Fed. App'x 404, 405 (8th Cir. 2018) (28 U.S.C. § 1631 allows a court to consider whether interests of justice require a case to be transferred when no personal jurisdiction exists).
However, many courts at both the appellate and district levels have found such transfers appropriate. See, e.g., Johnston v. Wilkins, 709 F. App'x 404, 405 (8th Cir. 2018) ("[D]istrict court should have considered whether the interest of justice required it to transfer the claim against [defendant] to the Northern District of Oklahoma (where the conduct occurred) rather than dismiss it."); Fed. Home Loan Bank of Bos. v. Moody's Corp., 821 F.3d 102 (1st Cir. 2016), abrogated on other grounds by Lightfoot v. Cendant Mortg. Corp., 137 S. Ct. 553 (2017); Freedman v. Suntrust Banks, Inc., 139 F. Supp. 3d 271 (D.D.C. 2015). And—significant for present purposes—the Eleventh Circuit is yet to definitively decide this issue.
However, in a recent unpublished opinion, the Eighth Circuit remanded a case for a district court to consider whether transfer was appropriate when the district court lacked personal jurisdiction. Johnston v. Wilkins , 709 F. App'x 404, 405 (8th Cir. 2018) ; see alsoPreston v. Wisc. Staffing Servs., Inc. , No. 12-797, 2012 WL 2906589, at *1 (D. Minn. July 16, 2012). As such, out of an abundance of caution, the Court proceeds with the Section 1631 analysis.