Chan v. Campanelli
- Laura Swain
- 1:25-cv-02981
- U.S. District Court · Southern District of New York
- 4
In Chan v. Campanelli, Judge Swain transferred the action to the Eastern District of New York because Brooklyn was the relevant forum.
Yu Hin Chan’s case was moved from the Southern District of New York to the Eastern District of New York. The order affected Chan, Joy F. Campanelli, and Christopher Gibson, but did not decide the merits of Chan’s allegations.
What happened
In Chan v. Campanelli, Yu Hin Chan, representing himself, sued Judge Joy F. Campanelli and Christopher Gibson over alleged misconduct involving his Kings County state-court matter and court-filing documents.
The court explained that the defendants’ residences were not stated, but the events described occurred in Kings County, which is in the Eastern District of New York. Chan also lives in Brooklyn and had previously litigated a related proceeding in that district, making it the more convenient forum.
Judge Laura Taylor Swain ordered the case transferred to the Eastern District of New York under the federal venue-transfer statute. The Southern District of New York case was closed, no summons would issue there, and that court denied fee-free appeal status because it certified that an appeal would not be taken in good faith.
The detailed version
- Chan v. Campanelli · No. 1:25-cv-02981
- Laura Swain
- Apr. 22, 2025
Background
Yu Hin Chan, who resides in Brooklyn, New York, filed the action without a lawyer against Joy F. Campanelli, a judge presiding over Chan’s state-court matter in Kings County, and Christopher Gibson, identified as the Director of the Division of E-Filing for the Office of Court Administration of the New York State Unified Court System. Chan alleged that Judge Campanelli forged multiple New York State Court Electronic Filing documents and that the Office of Court Administration failed to investigate her alleged conduct.
Chan did not state where either defendant resides. The opinion also refers to a prior related proceeding that Chan litigated in the Eastern District of New York, in which claims against Judge Campanelli were dismissed based on sovereign and judicial immunity.
Venue and Transfer
The court discussed the general venue statute, 28 U.S.C. § 1391(b). Because the defendants’ residences were unknown, venue might not be proper in the Southern District of New York based on where a defendant resides. The court stated, however, that even if venue were proper there, venue would also be proper in the Eastern District because the events underlying Chan’s claims occurred in Kings County.
Under 28 U.S.C. § 1404(a), a court may transfer a case to another district where it could have been brought when the transfer would serve the convenience of the parties and witnesses and the interests of justice. The court found transfer appropriate because Chan resides in Brooklyn, the underlying events occurred there, and Chan had already litigated a related proceeding in the Eastern District of New York.
Disposition
The court 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, stated that no summons would issue from that court, and left the decision about whether Chan could proceed without prepaying filing fees to the transferee court. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for an appeal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.