Shen-Shampas v. Rabow
- Edgardo Ramos
- 3:25-cv-04080
- U.S. District Court · Northern District of California
- 4
In Shen-Shampas v. Rabow, Judge Ramos transferred the case to California because the alleged events and defendants were there, and the parties agreed.
John H. Shen-Shampas and defendants Michael Rabow, Justin Sewell, and Becca Wallace are affected because the action was transferred from the Southern District of New York to the Northern District of California, and the Southern District case was closed.
What happened
John H. Shen-Shampas sued Michael Rabow, Justin Sewell, and Becca Wallace, alleging they violated California law by publishing false statements about his curriculum vitae submitted for a medical-residency application.
The court considered whether the case belonged in the Southern District of New York or the Northern District of California. The complaint identified San Francisco as the place where the events occurred, identified the defendants as located there, and both sides agreed that California was the proper venue.
Judge Edgardo Ramos ruled that transferring the case was in the interest of justice under federal venue law. He directed the Clerk to transfer the action to the Northern District of California and close the case; the order did not decide whether Shen-Shampas's claims were legally valid.
The detailed version
- Shen-Shampas v. Rabow · No. 3:25-cv-04080
- Edgardo Ramos
- Apr. 28, 2025
Background
John H. Shen-Shampas, representing himself, filed an action alleging that Michael Rabow, Justin Sewell, and Becca Wallace violated California Civil Code §§ 44–48.9 by publishing false statements concerning his curriculum vitae submitted with his application for medical residency.
The case was filed in the Southern District of New York. The court directed Shen-Shampas to explain why the action should not be transferred to the Northern District of California under 28 U.S.C. § 1404(a), a statute allowing transfer for the convenience of the parties and witnesses and in the interest of justice. Shen-Shampas and the defendants agreed that the Northern District of California was the proper venue.
Transfer analysis
The court explained that venue generally may be proper where a defendant resides or where a substantial part of the events giving rise to the claim occurred. It also explained that courts may transfer a case based on the overall circumstances, including the convenience of witnesses and parties, the location of relevant evidence, the place where the events occurred, and the interest of justice.
The court found that transfer was appropriate because, according to the complaint, the defendants were located in San Francisco, California, and the alleged place of occurrence was San Francisco. The record did not suggest that any substantial part of the events occurred in the Southern District of New York. The court therefore concluded that the Northern District of California was a proper venue and that the totality of the circumstances favored transfer.
Disposition
The court ordered the Clerk of Court to transfer the action to the United States District Court for the Northern District of California and close the case. The order resolved venue only; it did not decide the merits of Shen-Shampas's allegations or the defendants' proposed motion to dismiss.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.