Adams v. Judge Robert T. Watson
Michelle Adams v. Judge Robert T. Watson, in his official capacity in Florida’s 11th Judicial Circuit; Judge Ivan F. Fernandez, in his official capacity in Florida’s 3rd District Court of Appeals; Judge Bronwyn Miller, in his official capacity in Florida’s 3rd District Court of Appeals; Judge Alexander Bokor, in his official capacity in Florida’s 3rd District Court of Appeals; Mercedes M. Prieto, in her official capacity in Florida’s 3rd District Court of Appeals; John A. Tomasino, in his official capacity in the Florida Supreme Court; Miami-Dade Clerk of Court in its official capacity; Judge Lourdes Simon, in her official capacity in Florida’s 11th Judicial Circuit; Ariana Fajardo Orshan, in her official capacity in Florida’s 11th Judicial Circuit; and John/Jane Doe, in their official capacities in Florida’s court system.
- Laura Swain
- 1:25-cv-09915
- U.S. District Court · Southern District of New York
- 3
In Adams v. Watson, Judge Swain transferred the pro se federal case to Florida because venue was improper in New York.
Michelle Adams’s case was transferred from the Southern District of New York to the United States District Court for the Southern District of Florida. The order did not resolve her underlying claims or her request for injunctive relief.
What happened
Michelle Adams sued judges and court personnel connected to state courts in Miami, Florida, alleging violations of federally protected rights and asking to pause the underlying state-court proceedings. She filed the case in the Southern District of New York without a lawyer.
The court ruled that venue was improper in New York because the defendants worked in Miami and the alleged events occurred there. It transferred the case to the Southern District of Florida, rather than deciding whether Adams’s claims were valid or whether she should receive an injunction.
Judge Laura Taylor Swain ordered the transfer under the federal venue statute, closed the case in the Southern District of New York, and denied permission to proceed without paying fees for an appeal.
The detailed version
- Adams v. Judge Robert T. Watson · No. 1:25-cv-09915
- Laura Swain
- Dec. 3, 2025
Background
Michelle Adams brought this federal-question case without a lawyer. She alleged that judges and court personnel in several state courts in Miami, Florida, violated federally protected rights. She also sought an order pausing the underlying state-court proceedings.
Venue analysis
The court applied 28 U.S.C. § 1391, the federal venue statute. That statute generally permits a civil case to be filed where a defendant resides, where a substantial part of the events occurred, or, when neither of those options is available, where a defendant is subject to the court’s personal jurisdiction.
Adams did not allege where the defendants lived. But she alleged that the events giving rise to her claims occurred in state courts in Miami. The court concluded from the complaint that the defendants were employed in Miami and that the alleged events occurred there. It therefore held that venue was not proper in the Southern District of New York under the residence or events-based provisions of Section 1391.
Transfer and disposition
Under 28 U.S.C. § 1406(a), when a case is filed in the wrong venue, a court may dismiss it or, when justice requires, transfer it to a district where the case could have been filed. The court determined that the claims arose in Miami, which is in the Southern District of Florida, and transferred the action there in the interest of justice.
The Clerk of Court was directed to transfer the action immediately, without the usual seven-day delay. The court stated that the transferee court would decide whether Adams should receive injunctive relief. No summons would issue from the Southern District of New York, and the order closed the case there. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal.
The court did not decide the merits of Adams’s allegations or whether she was entitled to an injunction.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.