Murphy-Richardson v. United States
- Susan Van Keulen
- 5:21-cv-09507
- U.S. District Court · Northern District of California
- 2
In Murphy-Richardson v. United States, Judge Van Keulen transferred the case to Arizona because California was the wrong venue.
The transfer affects Ismael A. Murphy-Richardson, the United States, and the other defendants by moving the case from the Northern District of California to the District of Arizona.
What happened
Murphy-Richardson v. United States concerns claims by an Arizona state prisoner based on events during his Arizona criminal prosecution. The opinion states that most defendants are in Arizona and none are in California.
The court concluded that California was not the proper place for the case because the defendants were not located there and the relevant events did not occur there. It determined that the federal court in Arizona was the proper venue.
Judge Susan Van Keulen transferred the case to the U.S. District Court for the District of Arizona under the federal venue statute, directing the clerk to transfer it immediately.
The detailed version
- Murphy-Richardson v. United States · No. 5:21-cv-09507
- Susan Van Keulen
- Dec. 17, 2021
Background
Ismael A. Murphy-Richardson sued the United States and other defendants. The opinion states that he is an Arizona state prisoner located in Phoenix, Arizona, that most defendants are located in Arizona, and that his claims arise from events during his criminal prosecution in Arizona state court.
Venue analysis
The court explained that venue—the proper federal district in which a case may be litigated—is generally proper where a defendant resides, where a substantial part of the events occurred, or, in limited circumstances, where a defendant is subject to the court’s jurisdiction. The court found that venue was not proper in the Northern District of California because none of the defendants were located in California and the events underlying the claims did not occur there.
Under 28 U.S.C. § 1406(a), a federal court may dismiss a case filed in the wrong venue or transfer it to the proper federal court in the interest of justice. The court determined that the District of Arizona was the proper venue because the events giving rise to the claims took place there.
Disposition
Judge Susan Van Keulen ordered that the case be transferred to the United States District Court for the District of Arizona under 28 U.S.C. § 1406(a). The clerk was directed to transfer the matter immediately. The order addressed venue and did not decide the merits of the claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.