A federal judge in Delaware on Sept. 15 cited the district’s depleted bench as a reason for transferring a patent infringement suit against Apple Inc. to California, saying the case would have put an undue burden on an already overworked court.

The ruling from Judge Mark A. Kearney, visiting from the U.S. District Court for the Eastern District of Pennsylvania, came as Delaware’s district court continues to sort through an influx of patent cases following the U.S. Supreme Court’s May 22 ruling in TC Heartland, which tightened the rules defining proper venue. During that time, the U.S. District Court for the District of Delaware has been operating with just two active judges, after Judges Sue L. Robinson and Gregory M. Sleet announced earlier this year that they would be taking senior status.