Sandford v. Ganhito
Vanessa Sandford v. Paulina Ganhito; Elizabeth Groner; Enas Mousa; Kiara Espinosa
- Laura Swain
- 1:25-cv-06052
- U.S. District Court · Southern District of New York
- 4
In Sandford v. Ganhito, Judge Swain transferred Sandford’s pro se action to New Jersey because the alleged events occurred there.
Vanessa Sandford’s case was moved from the Southern District of New York to the District of New Jersey; the New Jersey court will decide whether she may proceed without prepaying fees.
What happened
Vanessa Sandford v. Paulina Ganhito; Elizabeth Groner; Enas Mousa; Kiara Espinosa concerns Sandford’s lawsuit under the federal Railway Labor Act. Sandford, representing herself, sought damages for events she said occurred at Newark Liberty International Airport and named four defendants who worked there.
The court said it was unclear whether the Southern District of New York was a proper location for the case because Sandford did not allege where the defendants lived. But the court found that the District of New Jersey was a proper location because the alleged events occurred at the airport in New Jersey. It also found New Jersey more convenient because relevant witnesses and documents would likely be there.
Judge Laura Taylor Swain ordered the case transferred to the District of New Jersey. The New York court closed the action there, did not issue summonses, and left any decision about allowing Sandford to proceed without paying filing fees to the receiving court. The court also denied fee-free status for any appeal.
The detailed version
- Sandford v. Ganhito · No. 1:25-cv-06052
- Laura Swain
- Sept. 12, 2025
Background
Vanessa Sandford filed this action without a lawyer, invoking federal-question jurisdiction and the Federal Railway Labor Act, 45 U.S.C. §§ 151–188. She sought damages based on events that she alleged occurred at Newark Liberty International Airport. The defendants were Paulina Ganhito, identified as a customer service agent and union representative; Elizabeth Groner, identified as a customer service team leader and union representative; Enas Mousa, identified as a customer service team leader; and Kiara Espinosa, identified as a ramp service agent.
Venue analysis
The court considered the federal venue statute, 28 U.S.C. § 1391(b). Sandford alleged that all defendants worked at the same location in Elizabeth, New Jersey, but she did not allege where they resided. The court therefore found it unclear whether venue was proper in the Southern District of New York under the provision concerning where defendants reside.
The court concluded that the District of New Jersey was a proper venue because Sandford alleged that the events underlying her claims occurred at Newark Liberty International Airport, which is in New Jersey. Sandford did not allege that a substantial part of the events occurred in the Southern District of New York.
Transfer ruling
Under 28 U.S.C. § 1404(a), a federal court may transfer a civil action to another federal district where it could have been brought when the transfer serves the convenience of the parties and witnesses and the interests of justice. The court determined that transfer was appropriate because a substantial part, if not all, of the alleged events occurred in New Jersey, making it reasonable to expect that relevant witnesses and documents would be located there.
The court ordered the Clerk of Court to transfer the action to the United States District Court for the District of New Jersey. It stated that the receiving court would decide whether Sandford could continue without prepaying fees. Summonses were not to issue from the Southern District of New York, and the order closed the action in that court. The court also certified that any appeal would not be taken in good faith and denied fee-free status for an appeal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.