Washington v. The People of The State of New York
- Laura Swain
- 1:25-cv-02485
- U.S. District Court · Southern District of New York
- 4
In Washington v. The People of The State of New York, Chief Judge Swain transferred the civil-rights case to the Eastern District of New York.
Jamel Washington’s case was moved from the Southern District of New York to the Eastern District of New York. The named defendants and the alleged events remain connected to the Richmond County proceedings; the transferee court will decide whether Washington may proceed without prepaying fees.
What happened
Washington v. The People of The State of New York concerns Jamel Washington’s lawsuit, filed without a lawyer under a federal civil-rights law, about his pending criminal proceedings in Richmond County. He named the People of the State of New York, a Richmond County judge, and two Richmond County prosecutors as defendants.
Judge Swain explained that Richmond County is in the Eastern District of New York and that the events, defendants’ work, relevant documents, and likely witnesses were connected to that district. The Eastern District therefore appeared to be the more convenient place for the case.
Chief Judge Laura Taylor Swain transferred the case to the United States District Court for the Eastern District of New York. The Southern District case was closed, no summons was issued there, and the court denied permission to proceed without paying appeal fees; the opinion did not decide whether Washington’s claims were valid.
The detailed version
- Washington v. The People of The State of New York · No. 1:25-cv-02485
- Laura Swain
- Mar. 27, 2025
Background
Jamel Washington, who was detained at the Eric M. Taylor Center on Rikers Island, brought this action without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. He alleged that the defendants violated his rights in connection with his pending criminal proceedings in the Richmond County Supreme Criminal Court. The defendants were the “People of the State of New York,” Richmond County Criminal Court Judge Alexander B. Jeong, Richmond County District Attorney Michael E. McMahon, and Richmond County Assistant District Attorney Kate C. Malloy.
Venue analysis
The court discussed the federal venue statute, 28 U.S.C. § 1391. Although Washington did not provide the defendants’ residential addresses, he provided Richmond County business addresses for each of them. Richmond County is in the Eastern District of New York. The court also concluded that, because the alleged events occurred in Richmond County, venue was proper there based on where a substantial part of the events occurred.
The court then applied 28 U.S.C. § 1404(a), which allows a court to transfer a case to another district where it could have been brought when the transfer would serve party and witness convenience and the interests of justice. The court found that the underlying events occurred in Richmond County, where the defendants worked and where the criminal prosecution was proceeding. It also considered it reasonable to expect that relevant documents and witnesses would be there.
Ruling
Chief United States District Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The order closed the case in the Southern District of New York, and a summons was not to issue from that court. The transferee court was left to decide whether Washington could proceed without prepaying filing fees. The court certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying appeal fees.
The opinion did not decide the merits of Washington’s civil-rights allegations. In a footnote, the court stated that claims against the State of New York, if that was what Washington intended by naming the “People of the State of New York,” would be barred by state sovereign immunity under the Eleventh Amendment; the court did not otherwise resolve those claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.