Williams v. B.R.C. of New York

Background

Clifton Clinton Williams, IV, who is detained at the North Infirmary Command on Rikers Island, brought the action without a lawyer. He alleged that staff at a BRC shelter at 146 Clay Street in Brooklyn forced him to leave without notice based on false accusations that he had stolen a laptop from an affiliated homeless shelter.

Transfer analysis

The court discussed the federal venue statute, which identifies the districts where a civil case may be filed. It stated that venue did not appear proper in the Southern District under the provision based on where the events occurred because Williams alleged that the events took place outside that district. The court noted that venue might still be proper there based on the defendants’ residence, but Williams had not provided enough facts for the court to make that determination.

The court found that venue was proper in the Eastern District of New York because Brooklyn is located there. It also considered the federal law allowing transfer for the convenience of the parties and witnesses and in the interest of justice. Because the underlying events occurred in Brooklyn, the court concluded that the Eastern District appeared to be a more convenient forum.

Ruling and effect

The court ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The order closed the case in the Southern District of New York, and no summons was to issue from that court. The transferee court will decide whether Williams may proceed without prepaying fees. The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The order transferred the case and did not resolve the truth of Williams’s allegations or the merits of his claims.