King-Knight v. State of New York

Background

Markus King-Knight brought four claims under 42 U.S.C. § 1983, alleging deprivation of rights under color of law, against the State of New York and several correctional and medical personnel, including unidentified John Doe and Jane Doe defendants. The court had previously ordered King-Knight to explain why the action should not be transferred to the Northern District of New York. King-Knight then advised the court that he did not object to transfer.

Venue analysis

The court applied 28 U.S.C. § 1391, which sets the permissible locations for filing a civil case. It found that venue was not proper in the Southern District of New York because the complaint did not allege that any defendant resided there or that a substantial part of the events or omissions underlying the claims occurred there. The court stated that many factual allegations concerned employees of, and events at, Upstate Correctional Facility, which appeared to be located in the Northern District of New York.

Under 28 U.S.C. § 1406(a), a court may dismiss a case filed in the wrong district or, when justice favors that result, transfer it to a district where the case could have been brought. The court chose transfer, reasoning that transfer would allow the case to be adjudicated efficiently and would better serve judicial economy.

Disposition

The court stated that it was transferring the action to the United States District Court for the Northern District of New York. However, the final instruction to the Clerk of Court directs transfer to the United States District Court for the Eastern District of New York. The opinion does not explain or resolve this inconsistency. The order addresses venue only and does not decide the merits of King-Knight’s claims.