Patrick di Santo v. New York State Unified Court System
- Laura Swain
- 1:25-cv-06674
- U.S. District Court · Southern District of New York
- 4
In Patrick di Santo v. New York State Unified Court System, Chief Judge Swain transferred the action to Northern New York because it was the more convenient forum.
Patrick di Santo's disability-accommodation claims were transferred from the Southern District of New York to the Northern District of New York; the merits were not decided.
What happened
Patrick di Santo, representing himself, sued the New York State Unified Court System under the Americans with Disabilities Act and the Rehabilitation Act. He alleged a systemic failure to provide reasonable accommodations during judicial proceedings in Ulster County and sought damages, court orders, and a declaration of his rights.
The Southern District of New York concluded that the Northern District of New York was a proper venue because the alleged events occurred in Ulster County. The court also determined that the Northern District appeared more convenient because relevant witnesses and documents were likely located there.
Chief Judge Laura Taylor Swain ordered the case transferred to the Northern District of New York under the federal transfer statute. The Southern District closed the case there, did not issue a summons, left any decision about proceeding without paying fees to the receiving court, and denied fee-free appeal status.
The detailed version
- Patrick di Santo v. New York State Unified Court System · No. 1:25-cv-06674
- Laura Swain
- Sept. 12, 2025
Background
Patrick di Santo, proceeding without a lawyer, brought claims under Title II of the Americans with Disabilities Act of 1990 and the Rehabilitation Act of 1973. He sued the New York State Unified Court System and requested damages, injunctive relief, and declaratory relief. He alleged a “systemic failure to provide reasonable accommodations during judicial proceedings in Ulster County,” New York.
Venue Analysis
The court applied 28 U.S.C. § 1391(b), the federal statute governing where a civil case may be filed. The court stated that it was unclear whether the New York State Unified Court System is an entity that can be sued. It explained that, if the plaintiff intended to sue the State of New York and the entity could be sued, the Southern, Northern, Eastern, and Western Districts of New York could each potentially be proper venues under the provision concerning where a defendant resides.
The court separately found that the Northern District of New York was a proper venue because the plaintiff alleged that a substantial part, possibly all, of the events underlying his claims occurred in Ulster County, which is in that district.
Transfer Decision
Under 28 U.S.C. § 1404(a), a federal 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 appeared appropriate because the alleged events occurred in the Northern District and relevant witnesses and documents could reasonably be expected to be there. It therefore ordered the case transferred to the United States District Court for the Northern District of New York.
Disposition
The court directed the Clerk to transfer the action and stated that the order closed the action in the Southern District of New York. It did not issue a summons. The receiving court was left to decide whether Patrick di Santo 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 opinion did not decide the underlying Americans with Disabilities Act or Rehabilitation Act claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.