Waters
- Susan Van Keulen
- 5:23-cv-06470
- U.S. District Court · Northern District of California
- 2
In Waters v. Los Angeles County Sherriff Deputies, Judge Van Keulen transferred the case to the Central District of California because venue was improper in the Northern District.
Waters and the unnamed Los Angeles County Sheriff Deputies defendants; the case was moved from the Northern District of California to the Central District of California.
What happened
In Waters v. Los Angeles County Sherriff Deputies, Waters, an inmate in the Los Angeles County Jail, sent a letter about confinement conditions and actions by unnamed Los Angeles County Sheriff Deputies. The Clerk told Waters to file a complaint on the court’s form.
The Northern District of California concluded that it was not the proper place for the case because the defendants were not located there and the events described occurred elsewhere. The court determined that the Central District of California was the proper federal court.
Judge Susan Van Keulen transferred the case to the United States District Court for the Central District of California under the federal venue statute. The Clerk was ordered to transfer the matter immediately.
The detailed version
- Waters · No. 5:23-cv-06470
- Susan Van Keulen
- Dec. 19, 2023
Background
Waters, an inmate in the Los Angeles County Jail, filed a letter complaining about the conditions of confinement and the actions of unnamed Los Angeles County Sheriff Deputies. The Clerk sent Waters a notice directing the filing of a complaint on the court’s complaint form.
Venue analysis
The court explained that venue generally is proper in a federal judicial district where a defendant resides, where a substantial part of the events or omissions giving rise to the claims occurred, or, in limited circumstances, where a defendant is subject to the court’s personal jurisdiction. The Northern District of California found that none of the defendants was located in that district and that the events underlying Waters’s claims did not occur there.
When a case is filed in the wrong venue, 28 U.S.C. § 1406(a) permits a district court either to dismiss the case or to transfer it to the proper federal court in the interest of justice. The court determined that the Central District of California was the proper venue because the defendants were located there and the events giving rise to the claims took place there.
Disposition
The court transferred the case to the United States District Court for the Central District of California under 28 U.S.C. § 1406(a) and ordered the Clerk to transfer the matter forthwith. The order did not dismiss the case or decide the merits of Waters’s confinement-related claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.