Steen v. Murray

(1) Whether the court erred in finding that a court interpreting 28 U.S.C. § 1391(b)(2) may consider only the activities of the defendants in determining whether venue is proper in a particular district; (2) whether the court erred in placing the burden on the plaintiffs to prove the venue was proper rather than on the defendants challenging venue; and (3) whether the court erred by failing to consider the "wrongful" nature of attorneys not licensed in Iowa representing Iowa clients in a transaction involving the ownership of real property in Iowa to determine if Iowa was a proper venue.