Medina v. New York State Division of Military and Naval Affairs
- Naomi Buchwald
- 1:24-cv-08512
- U.S. District Court · Southern District of New York
- 9
In Medina v. New York State Division of Military and Naval Affairs, Judge Buchwald ordered transfer to Western New York because the case’s events and participants are centered there.
The plaintiffs and defendants are affected because the case is being transferred from the Southern District of New York to the Western District of New York. The transfer ruling does not resolve the plaintiffs’ underlying claims.
What happened
Medina v. New York State Division of Military and Naval Affairs concerns claims by people connected to a state-funded migrant shelter in Cheektowaga, New York. The plaintiffs allege that defendants, including the New York State Division of Military and Naval Affairs and DocGo, engaged in unconstitutional conduct and state-law wrongdoing at the shelter.
The Southern District of New York considered whether the case should be moved to the Western District of New York. It found that the case could have been filed there and that the parties, witnesses, evidence, and alleged events were primarily connected to the Western District. The court rejected the plaintiffs’ arguments that their willingness to travel, remote testimony, or the location of attorneys justified keeping the case in Manhattan.
Judge Naomi Buchwald ordered that the case be transferred to the Western District of New York under the federal venue-transfer statute. The opinion decided where the case should proceed, not whether the plaintiffs’ underlying allegations were valid.
The detailed version
- Medina v. New York State Division of Military and Naval Affairs · No. 1:24-cv-08512
- Naomi Buchwald
- Dec. 10, 2024
Background
The plaintiffs include Florangelis Maria Cabreara Medina, Alexander Jose Vizcaino Marrufo, Kareema Washington, Erica Seymour, and anonymized individuals. They were guests of and/or employees at a privately run, state-funded Humanitarian Emergency Relief and Response Center in Cheektowaga, New York. The facility was established as a shelter for migrants and asylum seekers. The plaintiffs sued under 42 U.S.C. § 1983 and various state tort laws, alleging unconstitutional conduct that included physical violence and sexual exploitation.
The defendants include the New York State Division of Military and Naval Affairs, Rapid Reliable Testing NY, LLC doing business as DocGo, Deven Colon, Rigoberto Nuñez, and unnamed individuals. Colon is identified as a sergeant in the New York National Guard stationed at Cheektowaga, and Nuñez is identified as a DocGo employee at the shelter.
Transfer Question
The Southern District of New York had ordered the plaintiffs to explain why the case should not be transferred under 28 U.S.C. § 1404(a). That statute allows a federal court to transfer a civil case to another federal district where the case could have been brought if the transfer would serve the interest of justice.
The plaintiffs did not dispute that the case could have been brought in the Western District of New York. The remaining question was whether the interest of justice supported transfer. The court considered factors including the convenience of the parties and witnesses, the location of the events and evidence, the plaintiff’s choice of forum, the availability of compulsory process for witnesses, familiarity with the governing law, and the overall interests of justice.
Court’s Analysis
The court found that the Western District was substantially more convenient for the parties. The alleged conduct occurred at the Cheektowaga shelter, and the opinion states that all identifiable plaintiffs reside in Erie County. It also states that two defendants reside in Erie County, while the New York State Division of Military and Naval Affairs and DocGo operate more broadly and could litigate elsewhere in New York.
The court emphasized that the factual center of the case was in the Western District. Potential witnesses could include shelter employees, guests, and National Guard personnel at the site, and much of the evidence was likely to be located at or near the shelter. The Southern District had little connection to the alleged events or to the plaintiffs.
The court rejected the plaintiffs’ reliance on their willingness to testify in the Southern District and on the possibility of remote testimony. It also rejected the argument that DocGo’s connection to New York County or the National Guard’s statewide operations justified retaining the case. The court stated that the convenience of the parties’ attorneys, who had appeared from Manhattan, was not relevant to the transfer decision.
Disposition
Judge Naomi Reice Buchwald concluded that transferring the case would serve the interest of justice and was appropriate under § 1404(a). The court ordered that the case be transferred to the United States District Court for the Western District of New York and requested that the Clerk of Court carry out the transfer. The opinion did not decide the merits of the plaintiffs’ constitutional or state-law claims.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.