Thibodeau v. Kijakazi
- Joseph Spero
- 3:21-cv-06759
- U.S. District Court · Northern District of California
- 2
In Shawn A. Thibodeau v. Commissioner of Social Security, Judge Claire transferred the case to the Northern District of California because venue was improper.
Shawn A. Thibodeau's Social Security case was transferred from the Eastern District of California to the Northern District of California; the order did not decide his benefits claim.
What happened
Shawn A. Thibodeau, representing himself, filed a Social Security case in the Eastern District of California and moved to proceed without paying filing fees. He identified himself as living in Middletown Lake, California, in Lake County.
The court explained that Social Security cases must generally be filed in the federal district where the claimant lives or does business. Because Lake County is in the Northern District of California, the case was filed in the wrong district.
Judge Allison Claire ordered the case transferred to the Northern District of California in the interest of justice. The order did not decide the underlying Social Security claim.
The detailed version
- Thibodeau v. Kijakazi · No. 3:21-cv-06759
- Joseph Spero
- Aug. 31, 2021
Background
Shawn A. Thibodeau filed a Social Security action while representing himself and moved to proceed without paying filing fees. The opinion states that he identified himself as a resident of Middletown Lake, California, in Lake County.
Venue analysis
Under 42 U.S.C. § 405(g), judicial review of a final Social Security benefits decision generally belongs in the federal district where the claimant resides or has a place of business. The court determined that Lake County is within the Northern District of California. The action had instead been filed in the Eastern District of California.
Disposition
The court stated that a federal court may transfer a complaint filed in the wrong district to the correct district in the interest of justice under 28 U.S.C. § 1406(a). Judge Allison Claire ordered that the matter be transferred to the United States District Court for the Northern District of California. The order addressed venue and did not decide the merits of Thibodeau's Social Security claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.