Adams v. Newsom
- Jacquelyn Corley
- 3:20-cv-01325
- U.S. District Court · Northern District of California
- 2
In Adams v. Newsom, Judge Corley transferred the prisoners’ civil-rights case to California’s Eastern District for convenience.
The transfer affected Paul Adams and the other prisoner plaintiffs, the named defendants, and the plaintiffs’ requests to proceed without paying filing fees. The case was moved to the Eastern District of California, and the opinion did not resolve the underlying constitutional claim.
What happened
In Adams v. Newsom, California prisoners at the California Correctional Institute filed a civil-rights lawsuit without lawyers. They alleged that housing inmates in bunk beds violates the federal Constitution and sought to represent prisoners in state prisons and county jails statewide.
The court said venue was proper in the Northern District because the allegations involved events throughout California. But it found the Eastern District more convenient because the plaintiffs, defendants, and alleged violations were connected to that district. The court also said a statewide class was unlikely to be certified because prisoners representing themselves cannot adequately represent a class.
Judge Jacquelyn Corley transferred the case to the United States District Court for the Eastern District of California. The court deferred the plaintiffs’ requests to proceed without paying filing fees to that court and directed the clerk to close the case on the Northern District’s docket.
The detailed version
- Adams v. Newsom · No. 3:20-cv-01325
- Jacquelyn Corley
- May 13, 2020
Background
Paul Adams and other California prisoners filed this civil-rights action under 42 U.S.C. § 1983 without lawyers. They were housed at the California Correctional Institute in Tehachapi, California. They sought to represent a class of all inmates in California state prisons and county jails, alleging that housing inmates in bunk beds violates the federal Constitution.
The defendants were the Governor of California and the Secretary of the California Department of Corrections and Rehabilitation. The opinion states that both defendants were located in Sacramento, California. Tehachapi and Sacramento are within the Eastern District of California.
Venue and Transfer
The court explained that venue—the proper federal district for a case—was permitted in any California district because the class-wide allegations concerned events throughout the state. However, under 28 U.S.C. § 1404(a), a court may transfer a case for the convenience of the parties and witnesses and in the interest of justice when another federal district has a stronger connection to the case.
The court found the Eastern District more convenient because the plaintiffs and defendants were located there and the alleged violations took place there. The court also stated that certification of the proposed statewide class was unlikely because prisoners proceeding without lawyers are not adequate class representatives able to fairly represent and protect the class’s interests. The court added that the Eastern District would be more convenient even if the class were certified.
Ruling
Judge Jacquelyn Corley ordered that the case be transferred to the United States District Court for the Eastern District of California under 28 U.S.C. § 1404(a). The court deferred ruling on the plaintiffs’ motions for permission to proceed without paying filing fees and left those matters for the Eastern District. The clerk was directed to transfer the case and terminate docket numbers 2 and 3 from the Northern District’s docket. The opinion did not decide whether bunk-bed housing violates the Constitution or whether the proposed class should be certified.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.