Rankin v. The City of New York
- Laura Swain
- 1:25-cv-06493
- U.S. District Court · Southern District of New York
- 4
In Rankin v. The City of New York, Judge Swain transferred Rankin’s civil-rights case to the Eastern District of New York because Queens was the relevant location.
Adora Rankin’s case will proceed, if at all, in the Eastern District of New York rather than the Southern District of New York. The City of New York, Lieutenant Gatto, Officers Iacono and Marinaro, and the two unidentified officers are defendants in the transferred action. The receiving court will decide whether Rankin may proceed without prepaying filing fees.
What happened
In Rankin v. The City of New York, Adora Rankin, representing herself, sued the City of New York, Lieutenant Gatto, Officers Iacono and Marinaro, and two unidentified New York City police officers. She alleged that they violated her rights at her residence in Queens County.
The court explained that venue was proper in the Eastern District of New York because the events underlying the claims occurred in Queens. The court also found that Queens was where Rankin resides and where the individual officers work, making that district more convenient for witnesses and documents.
Judge Swain ordered the case transferred to the United States District Court for the Eastern District of New York. The Southern District court said the receiving court would decide whether Rankin could proceed without paying filing fees; no summons would issue from the Southern District, and the case was closed there.
The detailed version
- Rankin v. The City of New York · No. 1:25-cv-06493
- Laura Swain
- Aug. 12, 2025
Background
Adora Rankin, proceeding without a lawyer, brought an action under 42 U.S.C. § 1983. She alleged that the City of New York, Lieutenant Gatto, Police Officers Iacono and Marinaro, and two unidentified New York City police officers violated her rights at her residence in Jamaica, Queens County, New York.
The opinion notes that Rankin provided a mailing address at 99 Wall Street in New York, New York, but alleged that she resides in Jamaica, Queens. The court treated Queens as the location relevant to venue.
Venue
The court considered the federal venue statute, 28 U.S.C. § 1391. It explained that venue may be proper where defendants reside or where a substantial part of the events giving rise to the claims occurred. Queens County is within the Eastern District of New York.
The court stated that, assuming all defendants reside in New York State, venue could be proper in both the Southern and Eastern Districts of New York. But because the alleged events occurred in Queens County, venue was proper in the Eastern District under § 1391(b)(2).
Transfer decision
Under 28 U.S.C. § 1404(a), a court may transfer a case to another district where it could have been brought when transfer would promote the convenience of the parties and witnesses and the interests of justice. The court concluded that transfer appeared appropriate because the underlying events occurred in Queens, Rankin resides there, and the individual New York City police officers are employed there. The court also considered it reasonable to expect that relevant documents and witnesses would be in Queens County.
The court therefore transferred the action to the United States District Court for the Eastern District of New York. The Clerk of Court was directed to carry out the transfer.
Other rulings
The court left to the Eastern District whether Rankin may proceed without prepaying filing fees. It directed that a summons not issue from the Southern District of New York and stated that the case was closed in that court.
The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the transfer order would not be taken in good faith. It therefore denied permission to appeal without prepaying fees. The opinion does not decide whether Rankin’s underlying civil-rights allegations are valid.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.