Coffer v. Dugan
- Peterson
- 5:25-cv-03251
- U.S. District Court · Northern District of California
- 2
In Coffer v. Dugan, Judge Peterson transferred the civil-rights action to the Northern District of California because it was filed in the wrong district.
Jonathan Coffer’s civil-rights case was transferred from the Eastern District of California to the Northern District of California; the order did not decide the claim’s merits.
What happened
Jonathan Coffer, a state prisoner representing himself, sued Sierra Promise Dugan in a civil-rights action under federal law. He had not paid the filing fee or submitted an application to proceed without paying it.
The court explained that federal venue rules allow a case to be filed where the defendant resides or where a substantial part of the events occurred. The opinion states that Dugan was located in Alameda County and that the claim arose there, within the Northern District of California.
Judge Jeremy D. Peterson ordered the matter transferred to the Northern District of California in the interest of justice. The order transferred the case but did not decide the underlying civil-rights claim.
The detailed version
- Coffer v. Dugan · No. 5:25-cv-03251
- Peterson
- Apr. 9, 2025
Background
Jonathan Coffer, identified as a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983. The opinion states that he had not paid the filing fee and had not filed an application to proceed without paying it.
Venue Analysis
The court applied 28 U.S.C. § 1391(b), the federal venue statute. That statute permits a civil action to be filed in a district where a defendant resides, when the statutory conditions are met; where a substantial part of the events or omissions giving rise to the claim occurred; or, in certain circumstances, where a defendant is subject to the court’s personal jurisdiction.
The court stated that the defendant was located in Alameda County and that the claim arose there. Alameda County is in the Northern District of California. The court therefore concluded that the action should have been filed in that district rather than in the Eastern District of California.
Disposition
The court relied on 28 U.S.C. § 1406(a), which allows a federal court to transfer a case filed in the wrong district when doing so is in the interest of justice. It ordered that the matter be transferred to the United States District Court for the Northern District of California. The order did not reach the merits of Coffer’s civil-rights claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.