Brown v. New York State
- Laura Swain
- 1:25-cv-03429
- U.S. District Court · Southern District of New York
- 3
In Brown v. New York State, Judge Swain transferred the incarcerated plaintiff’s Section 1983 action to the Western District of New York.
The transfer affects Messiah D. Brown and the defendants in his Section 1983 action. The case will proceed, if allowed by the transferee court, in the Western District of New York rather than the Southern District of New York.
What happened
Brown v. New York State is a civil-rights case brought by Messiah D. Brown, who is incarcerated and representing himself. He claims that defendants violated his rights at Collins Correctional Facility in Erie County, New York.
The court concluded that the Southern District of New York was not the proper or most convenient location because the events and likely witnesses were connected to Collins Correctional Facility in the Western District of New York.
Judge Laura Taylor Swain ordered the case transferred to the Western District of New York and closed the case in the Southern District of New York. She also denied fee-free status for any appeal from the transfer order.
The detailed version
- Brown v. New York State · No. 1:25-cv-03429
- Laura Swain
- May 5, 2025
Background
Messiah D. Brown, who is incarcerated at Orleans Correctional Facility and is representing himself, brought claims under 42 U.S.C. § 1983. He alleges that defendants violated his rights at Collins Correctional Facility in Erie County, New York. The case was filed in the Southern District of New York.
Venue analysis
The court explained that federal law generally permits a civil case to be filed where a defendant resides, where a substantial part of the events occurred, or, in some circumstances, where a defendant is subject to the court’s authority. The court said it was unclear whether any defendant resided in the Southern District because Brown listed the defendants’ work addresses at Collins Correctional Facility.
The court found that the events underlying Brown’s claims occurred at Collins Correctional Facility, which is in the Western District of New York. It therefore stated that venue was proper there.
Transfer ruling
The court also considered whether transfer was appropriate for convenience and the interests of justice. It concluded that the Western District of New York appeared to be more convenient because the underlying events occurred there and the relevant witnesses could reasonably be expected to be there.
The court ordered the Clerk to transfer the action to the United States District Court for the Western District of New York. The order closes the case in the Southern District of New York; it does not decide the merits of Brown’s Section 1983 claims. The transferee court will decide whether Brown may continue without prepaying filing fees. No summons will issue from the Southern District of New York. The court also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal from this order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.