Valine v. United States Department of Labor
Jacob Valine v. United States Department of Labor; Lori Chavez-DeRemer, in her official capacity as Secretary of Labor
- Laura Swain
- 1:25-cv-08260
- U.S. District Court · Southern District of New York
- 3
In Valine v. United States Department of Labor, Chief Judge Swain transferred the pro se case to the District of Columbia because New York was an improper venue.
Jacob Valine's case was moved from the Southern District of New York to the United States District Court for the District of Columbia; the order did not resolve his claims against the Department of Labor or Lori Chavez-DeRemer.
What happened
Jacob Valine, who lives in Colorado, sued the United States Department of Labor and Secretary Lori Chavez-DeRemer over the shutdown of a Job Corps program he planned to attend. He said the shutdown denied him access to the program’s services.
The court ruled that the Southern District of New York was not a proper location for the case because the defendants did not reside there, the complaint did not allege that events occurred there, and Valine lived in Colorado. The court said the case could have been filed in Colorado or the District of Columbia.
Chief Judge Laura Taylor Swain transferred the case to the United States District Court for the District of Columbia in the interest of justice. The New York court closed the case there, issued no summons, and denied permission to appeal without prepaying fees.
The detailed version
- Valine v. United States Department of Labor · No. 1:25-cv-08260
- Laura Swain
- Oct. 14, 2025
Background
Jacob Valine, proceeding without a lawyer, sued the United States Department of Labor and Lori Chavez-DeRemer in her official capacity as Secretary of Labor. Valine alleged that he had been accepted into a Job Corps program funded and operated by the Department of Labor, but that the department shut down the program and denied him access to its services. The opinion states that Valine resides in Windsor Laramie, Colorado, and that he did not allege where the program was located.
Venue analysis
Because the defendants are federal defendants, the court applied 28 U.S.C. § 1391(e), which governs where such an action may be filed. The court concluded that venue was not proper in the Southern District of New York for any of the listed reasons: the defendants did not reside in a county within that district; the complaint did not allege that a substantial part of the relevant events occurred there; and the case did not involve real property, while Valine resided in Colorado.
Under 28 U.S.C. § 1406(a), a court may dismiss a case filed in the wrong venue or, when justice requires, transfer it to a district where it could have been filed. The court determined that Valine could have filed the action in the District of Colorado because he resides there or in the District of Columbia because the challenged federal actions occurred there and the Department of Labor and Secretary Chavez-DeRemer are located there.
Ruling
Chief United States District Judge Laura Taylor Swain ordered the Clerk of Court to transfer the action to the United States District Court for the District of Columbia under 28 U.S.C. § 1406(a). The order did not decide the underlying challenge to the Job Corps program’s shutdown. It stated that the transferee court would decide whether Valine could proceed without prepaying fees. The Southern District of New York case was closed, and no summons was to issue from that court.
The court also certified that any appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The opinion does not state the transferee court’s later action.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.