Lajoie v. Department of the Treasury
- Gregory Woods
- 1:25-cv-05815
- U.S. District Court · Southern District of New York
- 3
In J.A.P. Marc-Eddy Lajoie v. Department of the Treasury, Judge Woods transferred the case to Pennsylvania because venue was improper in New York.
J.A.P. Marc-Eddy Lajoie’s case will proceed, if otherwise appropriate, in the Eastern District of Pennsylvania rather than the Southern District of New York. The Department of the Treasury and the Internal Revenue Service are defendants in the transferred case. The court denied fee-free appeal status for an appeal from this order.
What happened
J.A.P. Marc-Eddy Lajoie sued the Department of the Treasury and the Internal Revenue Service, alleging that they billed him more than his actual tax liability even though he had paid his taxes. The court questioned why the case had been filed in the Southern District of New York.
The court found that Lajoie lived in Pennsylvania, the defendants were located elsewhere, and the relevant conduct and correspondence occurred outside New York. It also found that Pennsylvania would be more convenient for Lajoie, including because of his disability and access to an attorney in Philadelphia.
Judge Gregory H. Woods transferred the case to the Eastern District of Pennsylvania under the federal venue-transfer statute. The court also denied fee-free appeal status after certifying that an appeal would not be taken in good faith.
The detailed version
- Lajoie v. Department of the Treasury · No. 1:25-cv-05815
- Gregory Woods
- Aug. 19, 2025
Background
J.A.P. Marc-Eddy Lajoie brought this action against the Department of the Treasury and the Internal Revenue Service. He alleged that the defendants fraudulently billed him for more than his actual tax liability, despite his allegation that he had fully paid his tax obligations.
The court questioned whether venue—the legally proper location for a case—was appropriate in the Southern District of New York. The complaint did not explain why venue was proper there. The court noted that Lajoie resided in East Lansdowne, Pennsylvania; the Department of the Treasury and the Internal Revenue Service were identified as residing in Fresno, California, and Cincinnati, Ohio, respectively; the relevant officers were located in California and Ohio; and the disputed correspondence was mailed from Fresno, California.
Show-Cause Response and Transfer
The court had ordered Lajoie to explain why the case should not be transferred to the Eastern District of Pennsylvania. In response, Lajoie stated that he lived in Delaware County, Pennsylvania, and emphasized that litigating there would be more convenient because he had an attorney in Philadelphia and had a disability that limited his ability to stand or travel for extended periods.
The court concluded that venue did not lie in the Southern District of New York and that convenience and the interests of justice favored Pennsylvania. It also concluded that venue was appropriate in the Eastern District of Pennsylvania under 28 U.S.C. § 1391(e). The court therefore transferred the case to that district under 28 U.S.C. § 1406(a), a statute allowing transfer when a case is filed in the wrong federal district. The clerk was directed to transfer the case without delay and mail Lajoie a copy of the order.
Appeal Status and Disposition
Judge Gregory H. Woods certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith. The court therefore denied Lajoie fee-free status for an appeal. The order transferred the case; it did not decide the merits of Lajoie’s tax-related allegations.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.