Hickman v. City of New York
Quandell Hickman v. City of New York; N.Y.P.D. Coney Island, Brooklyn; John Doe N.Y.P.D.; Jane Doe N.Y.P.D.; John Doe A.D.A. Brooklyn Criminal Court
- Laura Swain
- 1:25-cv-08862
- U.S. District Court · Southern District of New York
- 4
Hickman v. City of New York: Judge Swain transferred Hickman’s civil-rights action to the Eastern District of New York because Brooklyn was the relevant location.
Quandell Hickman’s § 1983 action was transferred from the Southern District of New York to the Eastern District of New York. The transfer concerns where the case will proceed; the order did not decide the merits of his allegations.
What happened
In Quandell Hickman v. City of New York, Quandell Hickman, representing himself, alleged that he was falsely arrested in Brooklyn and later illegally searched and physically and sexually assaulted. He also alleged that the criminal charges were dismissed.
The court said the Southern District of New York might be a proper venue, but the Eastern District of New York was also proper because the alleged events occurred in Brooklyn. The court found that transfer was appropriate because relevant witnesses and documents would likely be in Brooklyn.
Chief Judge Laura Taylor Swain ordered the action transferred to the Eastern District of New York. She left the decision about whether Hickman could proceed without paying filing fees to that court, directed that no summons issue from the Southern District, closed the case there, and denied fee-free status for any appeal.
The detailed version
- Hickman v. City of New York · No. 1:25-cv-08862
- Laura Swain
- Oct. 28, 2025
Background
Quandell Hickman, who was incarcerated and litigating without a lawyer, brought an action under 42 U.S.C. § 1983. He alleged that he was falsely arrested in Coney Island in Brooklyn, New York, and then illegally searched and physically and sexually assaulted at a Brooklyn police station. He also alleged that the criminal charges were later dismissed. The defendants named in the complaint were the City of New York, the New York City Police Department, two unidentified police officers, and an unidentified Assistant District Attorney in Brooklyn.
Venue and Transfer
The court explained that venue is proper in a district where a substantial part of the events occurred. It said that it was unclear whether the Southern District of New York was proper under the separate rule concerning where defendants reside because Hickman did not identify all defendants’ residences. Even assuming that the Southern District was proper under that rule, the court found that the Eastern District of New York was also a proper venue because the alleged events occurred in Brooklyn, which is in Kings County and the Eastern District.
Under 28 U.S.C. § 1404(a), a court may transfer a case to another proper district for the convenience of the parties and witnesses and in the interest of justice. The court concluded that transfer appeared appropriate because the underlying events occurred in Brooklyn and the relevant documents and witnesses could reasonably be expected to be there. It therefore transferred the action to the United States District Court for the Eastern District of New York.
Disposition
The court directed the Clerk of Court to transfer the action to the Eastern District of New York. It stated that the transferee court would decide whether Hickman could proceed without prepaying fees. The Southern District court directed that no summons issue from that court and said that the order closed the case in the Southern District. It also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
The order addressed venue and transfer; it did not decide whether Hickman’s allegations were legally or factually valid.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.