Williams v. State of Mississippi

Background

Merlin Lkent Williams, who is imprisoned by the State of Mississippi, sued the State of Mississippi, various Mississippi officials and political subdivisions, and the National Criminal Information Center. Williams alleged that his incarceration violated his rights, which he characterized as property claims. The opinion states that neither Williams nor any of the 25 defendants had any connection to Minnesota.

A magistrate judge recommended dismissing the complaint. Williams objected to the recommendation, arguing that the Constitution does not address the proper venue for his case. The defendants did not object or respond to Williams’s objections.

Court’s analysis

The court reviewed the objected-to portions of the recommendation independently. Because Williams represented himself, the court read his objections and complaint liberally, but explained that he still had to meet federal pleading standards.

The court concluded that venue was improper in the District of Minnesota. Under the federal venue statute, a civil case generally may be filed where a defendant resides, where a substantial part of the events occurred, or, in some circumstances, where a defendant is subject to the court’s personal jurisdiction. The court found that no individual defendant resided in Minnesota and that no underlying event occurred there. It also found that Minnesota was not a proper venue for the National Criminal Information Center under the separate venue provision for federal agencies because Williams was not a Minnesota resident.

The court also concluded that the complaint failed to state a claim. Although Williams described the case as involving property, the court determined that the complaint challenged the validity of his conviction and confinement. Under the rule applied by the court, a claim seeking relief from a conviction or sentence must allege that the conviction or sentence has already been invalidated. Williams’s complaint did not make that allegation.

Because the complaint failed to state a claim, the court concluded that transferring the case to another district would not serve any purpose. The court therefore overruled Williams’s venue objection.

Other motions

Williams filed two applications to proceed without paying filing fees and a motion for leave to file the complaint. The court ruled that both fee applications were moot because it was dismissing the complaint. The motion for leave to file was also moot because it sought permission to file a document that had already been filed.

Disposition

Judge Wilhelmina M. Wright adopted the March 2, 2023 report and recommendation. The court dismissed the matter without prejudice under 28 U.S.C. § 1406(a), denied both applications to proceed without paying filing fees as moot, and denied the motion for leave to file as moot. The court directed that judgment be entered accordingly.