Anderson v. Rigner

Background

The order addressed seven cases brought by Juan V. Anderson in the District of Minnesota: No. 21-1076 against Mike Rigner et al.; No. 21-1126 against Henry Police Department et al.; No. 21-1127 against Michael Regnier et al.; No. 21-1128 against Erick Mund et al.; No. 21-1150 against Randy Yedinak et al.; No. 21-1151 against Bill Betram et al.; and No. 21-1152 against Tim Henson et al.

The court stated that, in each case, the defendants were alleged to reside in Illinois and none of the events at issue was alleged to have occurred in Minnesota. The court therefore concluded that the cases had been filed in the wrong federal district.

Venue and transfer

Federal law generally permits a civil case to be filed where a defendant resides, where a substantial part of the events occurred, or, if neither applies, where a defendant is subject to the court’s personal jurisdiction for the action. The court found that none of those conditions appeared on the face of the seven complaints.

Under 28 U.S.C. § 1406(a), a court may dismiss a case filed in the wrong district or transfer it if transfer would serve the interests of justice. The court concluded that transfer would not serve that interest. It said none of the seven pleadings described Anderson’s claims with even the minimum detail required by Rule 8(a)(2) of the Federal Rules of Civil Procedure. The court also said some, and perhaps all, of the cases appeared related to events involved in a matter that had already been transferred to the United States District Court for the Central District of Illinois.

Ruling

Judge Susan Richard Nelson ordered that each of the seven matters be dismissed without prejudice under § 1406(a), and directed that judgment be entered. The court stated that dismissal without prejudice would not prevent Anderson from pursuing any potentially viable claims in a more appropriate district. The order did not decide the merits of those claims.