Reeves v. United States Department of Justice

Background

Michael Reeves brought the action without a lawyer. His original complaint asserted federal constitutional claims against the United States Department of Justice. On May 14, 2025, the court transferred the action to the United States District Court for the Eastern District of New York under 28 U.S.C. § 1404, which allows a federal court to transfer a case to a more appropriate federal district.

Reeves later filed an amended complaint. The amended complaint continued to assert constitutional claims, added claims under the Federal Tort Claims Act, and named the Department of Homeland Security, the National Security Agency, and U.S. Immigration and Customs Enforcement as defendants.

Reasoning

The court determined that the transfer remained proper. For the constitutional claims, it relied on the reasoning in its earlier transfer order, including its statement that Reeves and the Department of Justice reside in Brooklyn and that the events underlying the claims occurred there.

For the Federal Tort Claims Act claims, the court applied 28 U.S.C. § 1402(b), which provides that such claims must be brought in the federal district where the plaintiff resides or where the complained-of act or omission occurred. The court stated that both conditions pointed to the Eastern District of New York because Reeves resides in Brooklyn and the amended complaint alleges that the relevant events occurred there.

Ruling

The court held that transfer of the action to the Eastern District of New York remained proper. It also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied Reeves permission to appeal without paying the required fees. The order did not decide the merits of Reeves’s constitutional or Federal Tort Claims Act claims.