Coffer v. Crayton
- McAuliffe
- 5:25-cv-02670
- U.S. District Court · Northern District of California
- 2
In Coffer v. Crayton, Judge McAuliffe transferred the prisoner’s civil-rights case to the Northern District of California because it belonged there.
The transfer affects Jonathan Christopher Coffer’s civil-rights action and the named defendants by moving the case from the Eastern District of California to the Northern District of California. The opinion does not identify the defendants beyond “Crayton, et al.”
What happened
In Coffer v. Crayton, Jonathan Christopher Coffer, a state prisoner representing himself, filed a civil-rights case under a federal law allowing claims against state officials. The case was filed in the Eastern District of California.
The court explained that federal venue rules generally require a case to be filed where a defendant resides or where the events occurred. It concluded that the claims appeared to arise in Monterey County, which is in the Northern District of California.
Judge Barbara A. McAuliffe ordered the case transferred to the Northern District of California in the interest of justice. The order resolved the filing location, not the underlying civil-rights claims.
The detailed version
- Coffer v. Crayton · No. 5:25-cv-02670
- McAuliffe
- Mar. 18, 2025
Background
Jonathan Christopher Coffer, identified as a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983. The opinion does not describe the substance of his claims.
Venue Analysis
The court applied the federal venue statute, 28 U.S.C. § 1391(b). That statute generally permits a civil action to be filed in a district where a defendant resides, where a substantial part of the events or omissions occurred, or, in limited circumstances, where a defendant is subject to the court’s personal jurisdiction.
The court stated that Coffer’s claims appeared to have arisen in Monterey County, which is in the Northern District of California. It therefore concluded that the case should have been filed in that district rather than the Eastern District of California.
Ruling
Under 28 U.S.C. § 1406(a), a federal court may transfer a case filed in the wrong district to the correct district in the interest of justice. Judge Barbara A. McAuliffe ordered that the matter be transferred to the United States District Court for the Northern District of California. The opinion did not rule on the merits of the civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.