Broadnax v. Newsom

Background

Cottrell Broadnax, an inmate housed at Kern Valley State Prison, filed a civil-rights action without a lawyer under 42 U.S.C. § 1983. The complaint explicitly named Gavin Newsom, Rob Bonta, Jeff Macomber, and Pat Horn, identifying them by their titles as California’s governor, attorney general, California Department of Corrections and Rehabilitation secretary, and warden of Kern Valley State Prison.

Broadnax initially filed fragments of documents and handwritten materials. After the clerk provided a prisoner civil-rights complaint form and a deadline, he filed additional documents and then filed the operative complaint on June 17, 2025. The court described that complaint as largely unintelligible. To the extent the court could understand it, Broadnax appeared to allege that he had committed no crimes or rule violations and that a jury trial occurred without his knowledge or consent and in his absence.

Venue analysis

Venue rules generally allow a case to proceed 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 personal jurisdiction. The complaint did not allege that any named defendant resided in the Northern District of California.

The court took judicial notice—meaning it accepted certain facts from sources whose accuracy could not reasonably be questioned—that Newsom’s office was in Sacramento, Bonta’s headquarters were in Sacramento, Macomber’s headquarters were in Elk Grove, and Horn’s office was at Kern Valley State Prison in Delano. The court also found that Newsom, Bonta, and Macomber were in Sacramento County and that Broadnax and Horn were in Kern County. Both counties are within the Eastern District of California.

The court concluded that all named parties were located in the Eastern District, no defendant was located in the Northern District, and none of the events at issue occurred in the Northern District. To the extent the complaint could be understood, the events occurred in the Eastern District. The court therefore found that venue properly lay in the Eastern District of California.

Authority to transfer

The court explained that a transfer for improper venue does not decide the claims, eliminate any defenses, or prevent the plaintiff from seeking relief. It also does not end the case in the federal court system; instead, the case continues in the receiving district. The court determined that a magistrate judge had authority to order the transfer because the transfer was not a ruling that disposed of the claims or defenses.

Under 28 U.S.C. § 1406(a), a district court may dismiss a case filed in the wrong venue or, in the interests of justice, transfer it to a district where the case could have been brought. The court exercised its discretion to transfer this case to the Eastern District of California.

Disposition

The court ordered that the action be transferred to the United States District Court for the Eastern District of California. It directed the clerk to close the case on the Northern District’s docket upon transfer. The order did not reach the merits of Broadnax’s civil-rights allegations.