In the case of Goldlawr, Inc. v. Heiman et al., 1961, the U.S Supreme Court ruled on a matter concerning venue transfer in federal courts. The petitioner, Goldlawr Inc., was sued by respondents for breach of contract and other claims in Pennsylvania's Eastern District court but sought to have the case transferred to New York's Southern District court where it believed it would receive fairer treatment due to its principal place of business being located there. However, this request was denied because Goldlawr wasn't technically doing business in that district and thus couldn't be served with process there under existing law at that time. The Supreme Court held that such restrictions were not applicable when considering venue transfers under Section 1406(a) which allows a case wrongly filed in an improper venue to be transferred rather than dismissed outright so as not to inconvenience parties involved unnecessarily. Therefore, even if a defendant is unable or unwillingly fails to establish contact within a particular jurisdiction doesn’t mean they can’t request their trial moved there from another district where they believe justice won’t prevail for them.

In the dissenting opinion for Goldlawr, Inc. v. Heiman et al., Justice Harlan argued that the majority's decision to allow a transfer of venue despite lack of personal jurisdiction over defendants contradicted established legal principles and precedent. He contended that such an approach could lead to forum shopping and manipulation by plaintiffs who may strategically file in one district with the intention of transferring to another more favorable location later on. Furthermore, he expressed concern about potential abuse where plaintiffs might deliberately choose districts where they know defendants cannot be served effectively just so they can then request a transfer under Section 1406(a). In his view, this would undermine fairness in litigation process as it gives undue advantage to plaintiffs while putting defendants at disadvantageous position without any fault on their part.