Rosol v. New York City Housing Authority
- Jesse Furman
- 1:25-cv-05183
- U.S. District Court · Southern District of New York
- 6
In Rosol v. New York City Housing Authority, Judge Furman ordered Christina E Rosol to explain why the case should not be transferred.
Christina E Rosol must respond within 30 days to avoid transfer of her case to the Eastern District of New York; NYCHA is affected by the potential change of court.
What happened
In Rosol v. New York City Housing Authority, Christina E Rosol, representing herself, sued her former employer over alleged discrimination based on race and Egyptian nationality, along with claims under the Family and Medical Leave Act. She alleges that the relevant events occurred while she worked in Staten Island.
The court found that the Eastern District of New York is a proper and likely more convenient venue because the work and alleged events occurred there and witnesses may be located there. The court has not yet transferred the case or decided whether Rosol’s claims have merit.
Judge Jesse M. Furman ordered Rosol to file a written declaration within 30 days explaining why the case should not be transferred to the Eastern District of New York. If she does not respond on time, the case will be transferred there without further notice.
The detailed version
- Rosol v. New York City Housing Authority · No. 1:25-cv-05183
- Jesse Furman
- July 1, 2025
Background
Christina E Rosol, appearing without a lawyer and proceeding without paying the filing fee, sued her former employer, the New York City Housing Authority (NYCHA). She alleges discrimination based on race and Egyptian nationality under 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, and New York State and City human-rights laws. She also invokes the Family and Medical Leave Act.
Venue analysis
The court explained that when a lawsuit includes multiple claims, venue generally must be proper for each claim. Rosol alleges that she worked in Staten Island, which is in Richmond County and therefore in the Eastern District of New York.
The court concluded that the Eastern District of New York is a proper venue for the Title VII claim because that is where Rosol worked. It also concluded that the Eastern District is a proper venue for the Section 1981 and Family and Medical Leave Act claims because a substantial part of the events occurred there. The court stated that venue also appears to be proper in both the Eastern and Southern Districts of New York based on NYCHA’s likely exposure to personal jurisdiction in both districts.
Potential transfer
Even when venue is proper, 28 U.S.C. § 1404(a) allows a court to transfer a case to another proper district for the convenience of the parties and witnesses and in the interest of justice. The court considered the location of the underlying events, the likely location of witnesses, and the reduced weight given to Rosol’s choice of forum because she resides in New Jersey and the alleged events occurred outside the Southern District of New York. The court stated that the Eastern District of New York appears to be the more convenient forum.
Order
The court directed Rosol to show cause by filing a written declaration within 30 days explaining why the action should not be transferred to the Eastern District of New York. The court has not yet ordered the transfer and did not decide the merits of Rosol’s discrimination or leave-related claims. If Rosol does not respond within the allowed time, the action will be transferred under Section 1404(a) without further notice.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.