Satchell v. Upstate of New York
- Laura Swain
- 1:25-cv-01780
- U.S. District Court · Southern District of New York
- 3
In Satchell v. Upstate of New York, Chief Judge Swain transferred the civil-rights action to New York’s Northern District because the alleged events occurred there.
John Satchell’s § 1983 action against Upstate of New York and unidentified correction officers was transferred from the Southern District of New York to the Northern District of New York.
What happened
Satchell v. Upstate of New York concerns John Satchell’s lawsuit against Upstate of New York and unidentified correction officers. Satchell, who is incarcerated at Clinton Correctional Facility, claimed that defendants violated his rights there.
The court explained that the events occurred in Clinton County, which is in the Northern District of New York. Because the facility, the defendants’ workplace, and expected documents and witnesses were there, the court found that district more convenient and transferred the action under federal venue law.
Chief Judge Laura Taylor Swain ordered the Clerk to transfer the action to the Northern District of New York. The case was closed in the Southern District of New York, no summons would issue from that court, and the court denied fee-free appeal status after certifying that an appeal would not be taken in good faith.
The detailed version
- Satchell v. Upstate of New York · No. 1:25-cv-01780
- Laura Swain
- Mar. 6, 2025
Background
John Satchell, who is incarcerated at Clinton Correctional Facility in Dannemora, New York, filed this action without a lawyer under 42 U.S.C. § 1983. He alleged that Upstate of New York and unidentified correction officers violated his rights at the facility.
Venue Analysis
The court considered federal venue rules under 28 U.S.C. § 1391. Satchell alleged that the events underlying his claims occurred at Clinton Correctional Facility, which is in Clinton County and therefore in the Northern District of New York. He did not allege the defendants’ residences, although he stated that the unidentified correction officers worked at Clinton Correctional Facility.
The court also applied 28 U.S.C. § 1404(a), which permits transfer to another federal district where the case could have been brought when transfer would promote convenience and the interests of justice. The court determined that transfer was appropriate because the underlying events occurred at the facility, Satchell was incarcerated there, the defendants worked there, and the relevant documents and witnesses could reasonably be expected to be there. The court concluded that the Northern District of New York appeared to be the more convenient forum.
Disposition
The court transferred the action to the United States District Court for the Northern District of New York. It directed the Clerk of Court to carry out the transfer, stated that the transferee court would decide whether Satchell could proceed without paying fees, and ordered that no summons issue from the Southern District of New York. The order closed the case in that court. Chief United States District Judge Laura Taylor Swain also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.