Jones v. Newsom

Background

Kevin Walker Jones, a state prisoner housed at Kern Valley State Prison and proceeding without a lawyer, filed a document titled “Notice of Objection and Reconsideration Petition for Writ of Habeas Corpus.” The court said the filing appeared to allege claims against medical personnel at the prison concerning the involuntary administration of psychiatric medication. Jones also challenged a September 8, 2020 order by an administrative law judge authorizing that medication.

Venue analysis

The court said the action might be either a habeas case—a case challenging the legality of custody—or a civil-rights case. If it were a habeas case, the court explained that the proper district was generally the district where Jones was confined because he was challenging conditions at his prison. Kern Valley State Prison is in Kern County, which is in the Eastern District of California.

If the filing were a civil-rights complaint, the court held that venue was also proper in the Eastern District under 28 U.S.C. § 1391(b), because the complained-of acts occurred at the prison and many named defendants reside in that district.

Disposition

Judge Kandis A. Westmore ordered the Clerk of Court to terminate any pending motions and transfer the case to the Eastern District of California. The order transferred the case without deciding whether the filing was a habeas petition or civil-rights complaint, and it did not reach the merits of Jones’s allegations.