Satchell v. Employee's of Dept. of D.O.C.C.

Background

John Satchell, who is currently incarcerated in the Clinton Correctional Facility, brought this action without a lawyer under 42 U.S.C. § 1983. The named defendants were “Employee’s of Dept of D.O.C.C. Clinton Correctional Facility,” the State of New York, and multiple unidentified correctional officers assigned to that facility. Satchell’s filings were styled for the Eastern District of New York, but the case was filed in the Southern District of New York.

Venue analysis

The court applied 28 U.S.C. § 1391(b), which generally permits a federal civil action to be brought where a defendant resides, where a substantial part of the events occurred, or, if neither of those options applies, where a defendant is subject to the court’s authority. Satchell did not allege where the defendants other than New York State resided, so the court said it was unclear whether venue was proper in the Southern District under the residence-based provision.

Satchell did allege that the events underlying his claims occurred at Clinton Correctional Facility. The court noted that the facility is in Clinton County, which lies within the Northern District of New York. It therefore concluded that the Northern District, rather than the Southern District, was a proper venue under the provision covering the place where the events occurred.

The court also applied 28 U.S.C. § 1404(a), which allows transfer to another federal district for the convenience of the parties and witnesses and in the interest of justice. It found transfer appropriate because the alleged events occurred at the facility in Clinton County, the individual defendants were alleged to be assigned there, and relevant documents and witnesses could reasonably be expected to be located in the Northern District.

Order

The court directed the Clerk to transfer the action to the United States District Court for the Northern District of New York. This order closed the action in the Southern District of New York. The court stated that the receiving court would decide whether Satchell could continue without prepaying filing fees, and summonses would not issue from the Southern District. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.

Disposition

The action was transferred to the Northern District of New York under 28 U.S.C. § 1404(a). The order did not decide the merits of Satchell’s civil-rights claims.