Turner v. Martinez County Jail
- Jacquelyn Corley
- 3:23-cv-04446
- U.S. District Court · Northern District of California
- 2
In Ronald Turner v. Martinez County Jail, Judge Delaney transferred the lawsuit to the Northern District of California because venue was improper in the Eastern District.
Ronald Turner’s lawsuit was moved from the Eastern District of California to the Northern District of California; the case caption names Martinez County Jail as the defendant.
What happened
Ronald Turner v. Martinez County Jail is a civil-rights lawsuit brought without a lawyer by a former county inmate under a federal civil-rights statute. Turner had not paid the filing fee or applied to proceed without paying it.
The court said the defendants were located and the events underlying the claim occurred in Contra Costa County, which is in the Northern District of California. It therefore found that the case should have been filed there.
The court transferred the matter to the U.S. District Court for the Northern District of California in the interest of justice. Judge Carolyn K. Delaney signed the order.
The detailed version
- Turner v. Martinez County Jail · No. 3:23-cv-04446
- Jacquelyn Corley
- Aug. 25, 2023
Background
Ronald Turner, a former county inmate proceeding without a lawyer, filed a civil-rights action under 42 U.S.C. § 1983 against Martinez County Jail. The opinion states that Turner had not paid the filing fee and had not submitted an application to proceed without paying it.
Venue analysis
The court applied the federal venue statute, 28 U.S.C. § 1391(b). That statute generally permits a civil action 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 determined that the defendants were located in Contra Costa County and that the claim arose there. Because Contra Costa County is in the Northern District of California, the court concluded that the action should have been filed in that district 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 order did not decide the merits of Turner’s civil-rights claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.