King-Knight v. State of New York
- Rochon
- 1:25-cv-01148
- U.S. District Court · Southern District of New York
- 3
In King-Knight v. State of New York, Judge Rochon transferred the civil-rights case to the Northern District of New York because venue was improper.
The case brought by Markus King-Knight against the State of New York and the named and unidentified defendants will proceed in the Northern District of New York instead of the Southern District of New York. The order did not decide whether the claims have merit.
What happened
In King-Knight v. State of New York, Markus King-Knight brought four civil-rights claims against New York State and correctional employees and medical personnel.
The Southern District of New York determined that venue was improper there because the complaint did not allege that any defendant lived in that district or that a substantial part of the relevant events occurred there. The complaint instead focused substantially on events and employees at Upstate Correctional Facility, which appears to be in the Northern District of New York.
The court transferred the case to the Northern District of New York rather than dismissing it, finding that transfer would serve the interests of justice. Judge Jennifer L. Rochon directed the Clerk of Court to complete the transfer.
The detailed version
- King-Knight v. State of New York · No. 1:25-cv-01148
- Rochon
- Feb. 28, 2025
Background
Markus King-Knight sued the State of New York, several correction officers, a sergeant, registered nurses, a physician assistant certified, and unidentified defendants. He asserted four claims under 42 U.S.C. § 1983, a federal law allowing claims for deprivation of rights under color of state law.
The case was filed in the Southern District of New York. On February 11, 2025, the court ordered King-Knight to explain why the case 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, the federal venue statute. It concluded 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 noted that a substantial portion of the complaint 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), when a case is filed in the wrong district, the court may dismiss it or, when serving the interests of justice, transfer it to a district where it could have been brought.
Ruling
The court found that transferring the action, rather than dismissing it, would allow the case to be adjudicated on its merits in an expeditious and orderly manner and would better serve judicial economy. Judge Jennifer L. Rochon therefore directed the Clerk of Court to transfer the action to the United States District Court for the Northern District of New York. The opinion did not decide the merits of King-Knight’s four claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.