Sreedhar v. Farrell
- Laura Swain
- 1:25-cv-01989
- U.S. District Court · Southern District of New York
- 3
In Sreedhar v. Farrell, Chief Judge Swain transferred the case to Massachusetts because venue was improper in New York.
The plaintiff's case was transferred from the Southern District of New York to the United States District Court for the District of Massachusetts. The transferee court will decide pending matters; no summons will issue from the New York court.
What happened
In Sreedhar v. Farrell, Sriknath Sreedhar, representing himself, sued Robert M. Farrell, the clerk of the federal court in Massachusetts. Sreedhar alleged that Farrell violated federal criminal statutes in connection with litigation in that court. The opinion states that Sreedhar resides in India, claims Massachusetts residency, and provided a Massachusetts address for Farrell.
The court found that the case belonged in the federal court district covering Boston, Massachusetts, where the alleged events occurred. It therefore transferred the case there under the federal venue-transfer law, rather than deciding whether Sreedhar’s claims were legally valid.
Chief Judge Laura Taylor Swain directed the clerk to transfer the action, stated that the receiving court would decide pending matters, and said no summons would issue from the New York court. The order closed the New York case and denied permission to appeal without paying filing fees because the court certified that an appeal would not be taken in good faith.
The detailed version
- Sreedhar v. Farrell · No. 1:25-cv-01989
- Laura Swain
- Mar. 14, 2025
Background
Sriknath Sreedhar brought this action without a lawyer, invoking federal-question and diversity jurisdiction. He alleged that Robert M. Farrell, identified as the clerk of the United States District Court for the District of Massachusetts, violated federal criminal statutes. The claims arose from litigation in that court. The opinion states that Sreedhar resides in India, claims to be a Massachusetts resident, and supplied a Massachusetts address for Farrell.
Venue analysis
The court applied 28 U.S.C. § 1391, which identifies the federal districts where a civil action may be filed. The court stated that Sreedhar did not plead Farrell’s residence, but alleged that the events supporting his claims occurred in Boston, Massachusetts. Because Farrell worked at the federal court in Boston and the alleged events occurred there, the court concluded that venue was not proper in the Southern District of New York under § 1391(b)(1) or § 1391(b)(2). The court determined that venue was proper in the District of Massachusetts under § 1391(b)(2).
Ruling and effect
Under 28 U.S.C. § 1406(a), a court may transfer a case filed in the wrong venue when transfer serves the interests of justice. The court transferred the action to the United States District Court for the District of Massachusetts. It directed that court to determine all pending matters. The Southern District of New York stated that a summons would not issue from that court and that the transfer order closed the case there. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied permission to appeal without paying filing fees.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.