Blaskowski v. Minnesota, State of

Background

Adam Blaskowski, who was representing himself, filed a complaint against the State of Minnesota and William Cashman in the United States District Court for the Western District of Michigan. The opinion says Blaskowski appears to seek relief under the Americans with Disabilities Act because his statement of claim consists only of the abbreviation “ADA.” The complaint identified Cashman’s address in St. Cloud, Minnesota, and did not allege that any events occurred in Michigan. A footnote says Cashman may be a judge of the Seventh Judicial Circuit in Stearns County, Minnesota, but the opinion does not definitively establish his identity or role.

Venue Analysis

Venue means the federal district where a case may properly be filed. The court discussed the general venue statute, 28 U.S.C. § 1391(b), and the special venue rules that apply to Americans with Disabilities Act employment claims through 42 U.S.C. §§ 12117(a) and 2000e-5(f)(3). It found that neither defendant resided in a county within the Western District of Michigan and that Blaskowski had not alleged events in Michigan. Based on the limited complaint, the court concluded that venue was proper only in the District of Minnesota.

Ruling

Under 28 U.S.C. § 1406(a), a court may transfer a case filed in the wrong district to a district where it could have been filed if doing so serves the interests of justice. Judge Ray Kent ordered that the case be transferred to the United States District Court for the District of Minnesota. The court did not decide Blaskowski’s motion to proceed without paying the filing fee. The opinion addresses venue only and does not decide the merits of the apparent Americans with Disabilities Act claim.