Sanchez v. Oronoz
- Laura Swain
- 1:25-cv-03594
- U.S. District Court · Southern District of New York
- 3
In Sanchez v. Oronoz, Chief Judge Swain transferred the improperly venued case to Puerto Rico and denied fee-free status for an appeal.
The transfer affects Maritza Ortiz Sanchez and the three named defendants by moving the action from the Southern District of New York to the District of Puerto Rico; the transferee court will decide whether Sanchez may proceed without prepaying fees.
What happened
In Sanchez v. Oronoz, Maritza Ortiz Sanchez, representing herself, sued three defendants over events involving her law-practice suspension and her child's removal from her custody in Puerto Rico. She also asked to proceed without paying court fees.
The court said the case did not belong in the Southern District of New York because the defendants were alleged to reside in Puerto Rico and the relevant events occurred there. It found that the District of Puerto Rico was a proper venue and transferred the case there.
Chief Judge Laura Taylor Swain ordered the transfer to the District of Puerto Rico's San Juan Division, leaving the fee question for that court. She also denied fee-free status for any appeal and closed the case in the Southern District of New York.
The detailed version
- Sanchez v. Oronoz · No. 1:25-cv-03594
- Laura Swain
- May 2, 2025
Background
Maritza Ortiz Sanchez filed the action without a lawyer and sought permission to proceed without prepaying court fees. She named Maite Oronoz, identified as the Chief Judge of the Supreme Court of Puerto Rico; Gina Mendez, identified as a United States District Judge in Puerto Rico; and Ana Lopez Prieto, identified as an attorney in Puerto Rico.
The opinion states that Sanchez's claims arose from her suspension in Puerto Rico from practicing law and from the removal in Puerto Rico of her minor child from her custody. It also states that she had filed numerous earlier suits in the District of Puerto Rico, including a pending related action filed in February 2025 against the same defendants, No. 3:25-CV-1118 (JL) (D.P.R.).
Venue Analysis
The court applied the general venue statute, 28 U.S.C. § 1391(b). It explained that a civil action may generally be filed where all defendants reside, where a substantial part of the events occurred, or, if neither of those options applies, where a defendant is subject to the court's personal jurisdiction.
The court concluded that venue was not proper in the Southern District of New York because the defendants were all alleged to reside in Puerto Rico and Sanchez alleged that the events giving rise to her claims occurred outside New York, in Puerto Rico. The court concluded that venue was proper in the District of Puerto Rico because the defendants resided there and the claims arose there.
Ruling
Under 28 U.S.C. § 1406(a), when a case is filed in the wrong venue, the court may dismiss it or, when justice requires, transfer it to a district where it could have been filed. The court transferred this action to the United States District Court for the District of Puerto Rico, San Juan Division.
The court stated that whether Sanchez could proceed without prepaying fees would be decided by the transferee court. It directed that no summons issue from the Southern District of New York and stated that the order closed the case in that court. It also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.