Carvajal v. United States of America
Irmatis Carvajal, individually and as the Administratrix of the Estate of Franklin Arturo Carvajal v. United States of America
- Philip Halpern
- 7:25-cv-06725
- U.S. District Court · Southern District of New York
- 3
Judge Halpern transferred Irmaris Carvajal v. United States to the Western District of New York because the events and evidence were centered there.
Irmaris Carvajal’s FTCA action against the United States will proceed, if at all, in the Western District of New York rather than the Southern District of New York.
What happened
In Irmaris Carvajal v. United States, Irmaris Carvajal sued the United States under the Federal Tort Claims Act over medical and nursing care allegedly provided at Geneva Community Health Clinic in Geneva, New York, which she says caused Franklin Arturo Carvajal’s death.
The Southern District of New York found that the case could have been filed in the Western District of New York because all events involved in the claims occurred in Geneva. It also found that the witnesses, documents, and other evidence would be located almost entirely in that district. Carvajal did not respond to the court’s order asking why the case should not be transferred.
Judge Halpern ordered the Clerk of Court to transfer the case to the Western District of New York and close the case in the Southern District of New York. The order did not decide whether Carvajal’s claims were legally valid.
The detailed version
- Carvajal v. United States of America · No. 7:25-cv-06725
- Philip Halpern
- Sept. 2, 2025
Background
Irmaris Carvajal, individually and as the Administratrix of the Estate of Franklin Arturo Carvajal, brought claims against the United States under the Federal Tort Claims Act (FTCA). She alleged that Franklin Arturo Carvajal suffered severe injuries and died because of careless and negligent medical and nursing care at Geneva Community Health Clinic in Geneva, New York.
The case was filed in the Southern District of New York. The court directed Carvajal to explain why the action should not be transferred to the Western District of New York. She did not respond.
Transfer analysis
The FTCA permits a claim to be filed in the judicial district where the plaintiff resides or where the alleged act or omission occurred. The court stated that venue was proper in the Southern District because Carvajal resides there. It nevertheless concluded that transfer was appropriate 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 applied the two-part transfer analysis: whether the case could have been brought in the proposed district and whether convenience and the interest of justice favored transfer. It found that all events underlying Carvajal’s claims occurred in Geneva, New York, which is in the Western District of New York. The court also found that the witnesses, relevant documents, and other sources of proof would be located almost exclusively there.
Disposition
The court ordered the Clerk of Court to transfer the case to the United States District Court for the Western District of New York under Local Civil Rule 83.1 and to close the case in the Southern District of New York. The transfer order did not reach the merits of the FTCA claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.