In Alla v. American University of Antigua, 106 AD3d 570, 965 N.Y.S.2d 469 (1st Dept 2013), the plaintiff was a California resident. The First Department affirmed the lower court's conclusion that New York was an inconvenient forum and lacked a "substantial nexus" to the Article 78 proceeding, which sought to annul a determination by the University's medical school. Although the First Department found that the "evidence does not support petitioner's contention that respondent the University has its principal office in New York," the nature of such evidence was not identified.