Sheldon v. San Quentin Staff
- Austin
- 3:23-cv-03554
- U.S. District Court · Northern District of California
- 2
In Sheldon v. San Quentin Staff, Magistrate Judge Austin transferred the federal civil-rights case to Northern California because the claim arose in Marin County.
The transfer affects Jeffrey Theodore Sheldon’s case against San Quentin Staff and others by moving it from the Eastern District of California to the Northern District of California; the order did not decide the claims’ merits.
What happened
In Sheldon v. San Quentin Staff, Jeffrey Theodore Sheldon, a state prisoner representing himself, filed a federal civil-rights case against San Quentin Staff and others under a federal civil-rights law.
The court said the claim arose in Marin County, which is in the Northern District of California. Because the case was filed in the wrong district, the court transferred it to the Northern District of California in the interest of justice.
Magistrate Judge Gary S. Austin ordered the transfer. The order did not decide the underlying civil-rights claims.
The detailed version
- Sheldon v. San Quentin Staff · No. 3:23-cv-03554
- Austin
- July 17, 2023
Background
Jeffrey Theodore Sheldon, a state prisoner proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against San Quentin Staff and others. The opinion states that the claim arose in Marin County.
Venue analysis
The court described the federal venue statute, 28 U.S.C. § 1391(b). That statute generally permits a civil case to be filed 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 personal jurisdiction. The court concluded that Marin County is in the Northern District of California, so the claim should have been filed there rather than in the Eastern District of California.
Disposition
Under 28 U.S.C. § 1406(a), a federal court may transfer a case filed in the wrong district when doing so serves the interest of justice. The court ordered that the matter be transferred to the United States District Court for the Northern District of California. The opinion did not address the merits of Sheldon’s civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.