Patterson v. Andes
- Edward Davila
- 5:25-cv-02819
- U.S. District Court · Northern District of California
- 1
In Patterson v. Andes, Judge Davila transferred a pro se confinement petition to California’s Central District because venue lay there.
Vester L. Patterson’s petition was transferred from the Northern District of California to the Central District of California; the order also terminated all pending motions in the transferring court.
What happened
Patterson v. Andes involved Vester L. Patterson, who was confined at San Quentin Rehabilitation Center and filed, without a lawyer, a petition challenging his confinement without a state-court finding of guilt.
The court explained that such a case may be heard where the person is confined or where the conviction occurred. Patterson identified Los Angeles County as the place of his challenged conviction, so the court determined that the Central District of California, rather than the Northern District, was the proper venue.
Judge Edward J. Davila transferred the case to the Central District of California under the federal venue-transfer statute. The clerk was ordered to terminate all pending motions and transfer the complete case file; the court did not decide whether Patterson’s confinement was lawful.
The detailed version
- Patterson v. Andes · No. 5:25-cv-02819
- Edward Davila
- Mar. 31, 2025
Background
Vester L. Patterson, who was confined at the San Quentin Rehabilitation Center, filed a petition under 28 U.S.C. § 2241 challenging his confinement without an “adjudication of guilt” in state court. The opinion identifies Warden Chance Andes as the respondent and states that Patterson filed the petition without a lawyer.
Venue Analysis
The court stated that venue for this type of petition is proper either in the district where the person is confined or in the district where the conviction occurred. It also explained that federal courts in California traditionally hear challenges to a conviction or sentence in the district of conviction or sentencing.
Patterson was challenging a conviction from Los Angeles County. The court found that Los Angeles County is within the Central District of California, specifically its Western Division. It therefore concluded that venue properly belonged in the Central District rather than the Northern District of California.
Ruling
The court ordered that the case be transferred to the United States District Court for the Central District of California under 28 U.S.C. § 1406(a), the federal statute permitting transfer when venue is improper. The clerk was directed to terminate all pending motions and transfer the entire file to the Central District’s Western Division.
The order addressed venue and transfer only. It did not decide the merits of Patterson’s challenge to his confinement.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.