James v. Supreme Court of Kings County

Background

Miguel James, who was detained at West Facility on Rikers Island and represented himself, sued the Supreme Court of Kings County, the District Attorney of Kings County, Mitchell Salaway, Gwen Barnes, and Kim Petersen. He brought claims under 42 U.S.C. § 1983 arising from his pending criminal proceedings in Kings County, New York.

Venue analysis

The court discussed the general federal venue statute, which identifies districts where a civil action may be filed based on defendants’ residence or where a substantial part of the events occurred. The court said it was unclear whether venue was proper in the Southern District under the residence provision because James had not alleged where the defendants were domiciled.

The court determined that venue was proper under the events-based provision in the Eastern District of New York because Kings County is within that district. The court also applied 28 U.S.C. § 1404(a), which allows transfer for the convenience of the parties and witnesses and in the interest of justice. It concluded that transfer was appropriate because the underlying events occurred in Kings County and relevant documents and witnesses could reasonably be expected to be there.

Ruling

Chief Judge Laura Taylor Swain ordered the action transferred to the United States District Court for the Eastern District of New York. The clerk was directed to transfer the action, no summons was to issue from the Southern District, and the Southern District case was closed. The order left the decision about whether James could proceed without prepaying fees to the transferee court. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not resolve the merits of James’s section 1983 claims.