Ryan Randolph v. New York City/State; Mid-State; Clinton; Fishkill
- Laura Swain
- 1:25-cv-08130
- U.S. District Court · Southern District of New York
- 5
In Ryan Randolph v. New York City/State, Judge Swain transferred the action to the Northern District of New York over venue and convenience.
Ryan Randolph’s case was transferred from the Southern District of New York to the Northern District of New York. The Northern District will decide whether he may proceed without prepaying filing fees and will handle any further proceedings.
What happened
In Ryan Randolph v. New York City/State; Mid-State; Clinton; Fishkill, Ryan Randolph, who is incarcerated and representing himself, claimed that the defendants violated his constitutional rights by failing to provide food he considers properly halal. He sought damages and halal meals for Muslim prisoners.
The court did not decide whether Randolph’s claims were valid. It concluded that the Northern District of New York was a proper and more convenient venue because the events concerning Randolph’s own claims appeared to be occurring at Mid-State, and relevant witnesses and documents were likely there. The court transferred the action to that district and closed the case in the Southern District of New York.
Judge Laura Taylor Swain directed the Clerk of Court to transfer the action. She left the decision about Randolph’s ability to proceed without paying filing fees to the Northern District court, ordered that summonses would not issue from the Southern District, and denied fee-free status for any appeal from the order.
The detailed version
- Ryan Randolph v. New York City/State; Mid-State; Clinton; Fishkill · No. 1:25-cv-08130
- Laura Swain
- Oct. 16, 2025
Background
Ryan Randolph, who is incarcerated at Mid-State Correctional Facility and is proceeding without a lawyer, brought an action that the court construed as asserting constitutional claims under 42 U.S.C. § 1983. He appeared to name the City of New York, the State of New York, Mid-State, Clinton Correctional Facility, and Fishkill Correctional Facility as defendants. He sought $8 million in damages and a halal menu for Muslim people in the City and State.
Randolph appeared to allege that, while incarcerated at Auburn Correctional Facility about five years earlier, he successfully grieved the provision of halal food. He further appeared to allege that prison officials were not providing food that was properly halal under his interpretation of the Quran. The court explained that, because Randolph was proceeding without a lawyer, he could assert claims only on his own behalf and not on behalf of other Muslim prisoners.
Venue Analysis
The court applied 28 U.S.C. § 1391(b), which identifies federal districts where a civil action may be filed. It stated that the City of New York and Fishkill were located in, or associated with, the Southern District of New York, while Mid-State and Clinton were within the Northern District. The court also stated that the State of New York resided in all four federal districts within the state. Assuming all defendants had the capacity to be sued, the court concluded that the Southern District and the other New York federal districts were proper venues under § 1391(b)(1).
The court was not sure that the Southern District was a proper venue under § 1391(b)(2), which concerns where a substantial part of the events occurred. It concluded, however, that the Northern District was a proper venue because the events relevant to Randolph’s own claims appeared to be occurring at Mid-State in Oneida County. The court also considered transfer under 28 U.S.C. § 1404(a), which permits transfer to another proper federal district for the convenience of the parties and witnesses and in the interest of justice. It found that the Northern District appeared more convenient because the underlying events occurred there and relevant documents and witnesses could reasonably be located there.
Ruling
Judge Laura Taylor Swain directed the Clerk of Court to transfer the action to the United States District Court for the Northern District of New York. The order closed the action in the Southern District of New York, and summonses were not to issue from that court. The court deferred to the Northern District on whether Randolph could proceed without prepaying filing fees, including whether the Prison Litigation Reform Act’s three-strikes rule applied. The court also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal. The court did not decide the merits of Randolph’s constitutional claims.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.