Rankin v. The City of New York
- Laura Swain
- 1:25-cv-06493
- U.S. District Court · Southern District of New York
- 4
Rankin v. The City of New York: Chief Judge Swain transferred the action to the Eastern District of New York because Queens was the relevant location.
Adora Rankin’s case was moved from the Southern District of New York to the Eastern District of New York. The transfer concerns the court handling the case and did not decide Rankin’s claims against the City of New York or the named NYPD officers.
What happened
In Rankin v. The City of New York, Adora Rankin, representing herself, sued the City of New York and NYPD officers under a federal civil-rights law. She alleged that her rights were violated at her residence in Queens County.
The court explained that the case could be heard in either the Southern or Eastern District of New York under the venue rules, but the events, plaintiff, officers, witnesses, and documents were connected to Queens. The court therefore found the Eastern District more convenient.
Chief Judge Laura Taylor Swain ordered the case transferred to the Eastern District of New York. The Southern District case was closed, no summons would issue there, and the court denied fee-free appeal status; the transferee court would decide whether Rankin could continue without paying filing fees.
The detailed version
- Rankin v. The City of New York · No. 1:25-cv-06493
- Laura Swain
- Aug. 12, 2025
Background
Adora Rankin filed this action without a lawyer under 42 U.S.C. § 1983, alleging that the defendants violated her rights at her residence in Jamaica, Queens County. The defendants named in the caption are the City of New York; NYPD Lieutenant Gatto; NYPD Officers Iacono and Marinaro; and two unidentified NYPD officers. The opinion does not decide the underlying allegations.
Venue
The court explained that venue rules allow a civil case 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 the court’s authority. Queens County is in the Eastern District of New York. Although Rankin did not provide residential addresses for the individual defendants, the court stated that the City of New York is considered to reside in both the Southern and Eastern Districts of New York. Assuming all defendants reside in New York State, venue was proper in both districts under one venue provision. Venue was also proper in the Eastern District because the events underlying the claims occurred in Queens.
Transfer decision
Under 28 U.S.C. § 1404(a), a court may transfer a case to another proper federal district for the convenience of the parties and witnesses and in the interest of justice. The court concluded that transfer was appropriate because the events occurred in Queens, Rankin resides there, and the individual NYPD officers are employed there. The court also considered it reasonable to expect that relevant documents and witnesses would be in Queens.
Disposition
The court ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The case was closed in the Southern District of New York, and a summons was not to issue from that court. The opinion states that the Eastern District would decide whether Rankin could proceed without prepaying filing fees. The court also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal. The order did not resolve the merits of Rankin’s civil-rights claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.