Maiola v. Greater Baltimore Medical Center

Background

Joseph N. Maiola, who lives in Yuma, Arizona and was representing himself, sued Greater Baltimore Medical Center. He claimed that in 1978 there was a planned switch of a newborn baby at the Center with another newborn, causing severe emotional distress to him and his family. The opinion identifies Maiola as the baby’s father. The opinion states that all events occurred in Maryland and that the Center is located in Towson, Maryland.

Venue

Venue is the proper federal district for a case. The court explained that federal law generally allows a civil case to be filed where the defendant resides or where a substantial part of the events occurred. Because the defendant and the events were in Maryland, the court concluded that venue was not proper in the Northern District of California.

The court had previously ordered Maiola to explain why the case should not be transferred to the District of Maryland for lack of venue. Maiola responded with reasons including alleged bias, travel time, emotional distress, and convenience. The court concluded that those reasons did not affect venue or the court’s lack of personal jurisdiction over the Center.

Ruling

The court transferred the case to the District of Maryland under the federal law allowing transfer when venue is improper and transfer serves the interests of justice. It did not dismiss the case. The order also attached the court’s earlier screening order, which summarized the facts and cited relevant law. Judge Laurel Beeler entered the order on December 9, 2019.