Young v. Doe

Background

Ricky D. Young, who is incarcerated at the Eric M. Taylor Center on Rikers Island, filed this action without a lawyer under 42 U.S.C. § 1983, a federal law that permits claims against state or local officials for violating federal rights. He sued an unidentified Queens Assistant District Attorney, two unidentified police officers, and the City of New York. He said that his claims arose at the Queens Criminal Court and at a hospital in Flushing.

Venue and Transfer

Venue is the legally proper geographic location for a lawsuit. Under 28 U.S.C. § 1391, a civil action may generally be filed where the defendants reside or where a substantial part of the events occurred. The court found that venue was not proper in the Southern District of New York based on where the events occurred because Young alleged that those events took place in Queens County. The court said it was unclear whether venue was proper there based on the defendants’ residences.

Queens County is in the Eastern District of New York, so venue was proper there based on the location of the events. The court also applied 28 U.S.C. § 1404(a), which permits transfer for the convenience of the parties and witnesses and in the interest of justice. It determined that transfer was appropriate because the underlying events occurred in Queens County and witnesses and relevant documents could reasonably be expected to be there.

Ruling

The court transferred the action to the United States District Court for the Eastern District of New York. The Clerk of Court was directed to transfer the action, and the Southern District of New York case was closed. A summons was not to issue from the Southern District. The court left it to the Eastern District to decide whether Young could proceed without prepaying filing fees. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.