Sanchez v. CDCR California

Background

Benjamin C. Sanchez, who represented himself, sued CDCR California and two individual defendants. The opinion states that the claims arose from events at a CDCR facility in San Luis Obispo County. The individual defendants appeared to be either employees of or people incarcerated at the facility.

Venue analysis

Venue is the proper federal court location for a case. Under 28 U.S.C. § 1391(b), venue generally is proper where a defendant resides, where a substantial part of the events occurred, or, in limited circumstances, where a defendant is subject to the court’s personal jurisdiction. The court concluded that the Northern District of California was not the proper venue because all events giving rise to the claims occurred in the Central District. It stated that the individual defendants appeared to reside in San Luis Obispo County, in the Central District, while CDCR was headquartered in Sacramento, in the Eastern District.

The court also stated that CDCR appeared to be immune from suit under the Eleventh Amendment to the United States Constitution. The opinion did not decide whether that immunity ultimately applied or resolve the merits of Sanchez’s claims.

Disposition

When a case is filed in the wrong venue, 28 U.S.C. § 1406(a) allows the court to dismiss the case or transfer it to a proper federal court in the interest of justice. The court chose transfer and ordered the Clerk to transfer the action to the United States District Court for the Central District of California. Judge Susan Van Keulen did not rule on the underlying claims.