Stevens v. SBMC

Background

Dean Michael Stevens, identified in the order as a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against SBMC and others. He also filed an application to proceed without paying the filing fee under 28 U.S.C. § 1915.

Venue analysis

The court applied the federal venue statute, 28 U.S.C. § 1391(b). That statute identifies locations where a civil case may be filed, including the district where a substantial part of the events giving rise to the claim occurred. The court found that Stevens’s claim arose in Mendocino County, which is located in the Northern District of California.

Because the action had been filed in the Eastern District of California, the court determined that it was filed in the wrong district. Under 28 U.S.C. § 1406(a), a federal court may transfer a case filed in the wrong district to the correct district when doing so serves the interests of justice.

Ruling

Judge Sean C. Riordan ordered that the matter be transferred to the United States District Court for the Northern District of California. The order transferred the case based on venue and did not resolve the merits of Stevens’s civil-rights claims or state how the court would rule on his fee-waiver application.

Disposition

The matter was transferred to the United States District Court for the Northern District of California.