Teague v. City of New York
- P. Castel
- 1:25-cv-01493
- U.S. District Court · Southern District of New York
- 4
In Teague v. City of New York, Judge Castel transferred the case to the Eastern District of New York because the events and plaintiff were in Brooklyn.
Kenneth Teague, the City of New York, and the eight unidentified New York City police officers are affected because the case was transferred from the Southern District of New York to the Eastern District of New York.
What happened
Kenneth Teague sued the City of New York and eight unidentified New York City police officers under a federal civil-rights law. He alleged that the events occurred in Brooklyn but argued that the Southern District of New York was a proper venue because the City had a presence there.
The court considered whether to move the case for the convenience of the parties and witnesses and in the interest of justice. It found that the events occurred entirely in Brooklyn, Teague lived in Brooklyn, and relevant witnesses and documents would likely be there.
Judge P. Castel ordered the case transferred to the Eastern District of New York and directed the Clerk of Court to close the case in the Southern District. The court did not decide the underlying civil-rights claims.
The detailed version
- Teague v. City of New York · No. 1:25-cv-01493
- P. Castel
- June 3, 2025
Background
Kenneth Teague brought claims under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state or local actors, against the City of New York and eight unidentified New York City police officers. The complaint identified Teague as living in Kings County and alleged that the relevant incidents occurred entirely in Brooklyn.
The case was filed in the Southern District of New York. The court ordered the parties to explain why the action should not be transferred to the Eastern District of New York, where it could have been brought. Teague argued that venue was proper in the Southern District because the New York City Police Department maintained a place of business there and because the City was the sole corporate defendant with a presence in that district. The City filed no response to the transfer order.
Transfer Analysis
Under 28 U.S.C. § 1404(a), a federal court may transfer a case to another federal district where it could have been brought when transfer would serve the convenience of the parties and witnesses and the interests of justice. The court considered the relevant factors, including the convenience of witnesses and parties, the location of the events, access to documents and other evidence, and the interests of justice.
The court concluded that transfer was appropriate because the underlying events occurred entirely in Brooklyn and Teague lived there. It reasoned that relevant documents and witnesses would reasonably be expected to be located in Brooklyn. If the case proceeded to trial, the court found that the interests of justice favored having the claims decided by a jury in the Eastern District, where the local controversy occurred.
The court found that the factors concerning witness convenience, party convenience, the location of the events, access to evidence, and the interests of justice favored transfer. The remaining factors were neutral. No factor favored keeping the case in the Southern District. Because Teague did not live in the Southern District and the events did not occur there, the court gave no weight to his choice of venue.
Ruling
Judge P. Castel ordered the case transferred to the United States District Court for the Eastern District of New York. The Clerk of Court was directed to transfer the action and close the case. The opinion addressed venue and transfer only; it did not decide whether Teague’s civil-rights claims were valid.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.