Pina v. State Farm Mutual Automobile Insurance Company
- Laura Swain
- 1:25-cv-06589
- U.S. District Court · Southern District of New York
- 3
Pina v. State Farm, Judge Swain transferred the case to California because the events and related litigation were there.
Frederick Pina and State Farm Mutual Automobile Insurance Company; the case will proceed, if at all, in the Central District of California rather than the Southern District of New York.
What happened
In Pina v. State Farm Mutual Automobile Insurance Company, Frederick Pina, representing himself, claimed that State Farm breached a contract related to litigation in California. He invoked the court’s authority over disputes between citizens of different states.
The Southern District of New York concluded that California was the proper venue because the events underlying the claims occurred there. It also found that transfer was appropriate because Pina lives outside the district, the claims rely on California law, and the same issue had already been raised in a pending related case in the Central District of California.
Judge Laura Taylor Swain ordered the case transferred to the Central District of California and closed the case in the Southern District of New York. She also denied permission to proceed without prepaying fees for any appeal, finding that an appeal would not be taken in good faith.
The detailed version
- Pina v. State Farm Mutual Automobile Insurance Company · No. 1:25-cv-06589
- Laura Swain
- Aug. 11, 2025
Background
Frederick Pina brought this action without a lawyer against State Farm Mutual Automobile Insurance Company. He invoked diversity jurisdiction, which allows certain federal cases involving parties from different states, and asserted breach-of-contract claims arising from litigation between the parties in California. The opinion states that he had also raised the same breach-of-contract issue in a pending related proceeding in the Central District of California.
Venue and Transfer
The court first explained that federal law generally permits a civil action to be filed where a defendant resides, where a substantial part of the events occurred, or, in limited circumstances, where a defendant is subject to personal jurisdiction. The court concluded that venue in the Southern District of New York did not appear proper based on where the events occurred because Pina’s claims concerned litigation in California. It stated that venue was proper in the Central District of California.
The court also considered transfer under 28 U.S.C. § 1404(a), which permits transfer for the convenience of the parties and witnesses and in the interest of justice. The court noted that Pina resides in Staten Island, outside the Southern District of New York; that the underlying events occurred in California; that Pina relies on California law; and that the same issue had already been raised in a pending related case in the Central District of California. The court determined that the Central District of California appeared to be the more appropriate forum.
Ruling
The court ordered the Clerk of Court to transfer the action to the United States District Court for the Central District of California. The order closed the case in the Southern District of New York, stated that the transferee court would decide whether Pina could proceed without prepaying fees, and directed that no summons issue from the Southern District of New York. The court also certified that any appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal. The court did not decide the underlying breach-of-contract claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.