Jiggetts v. State of Maryland
- Colleen McMahon
- 1:20-cv-04910
- U.S. District Court · Southern District of New York
- 3
In Jiggetts v. State of Maryland, Judge McMahon transferred the case to Maryland because venue was improper in New York.
Alexander Jiggetts’s § 1983 case against the State of Maryland was transferred to the U.S. District Court for the District of Maryland; that court would decide whether he could proceed without prepaying fees.
What happened
In Jiggetts v. State of Maryland, Alexander Jiggetts, representing himself, claimed discrimination and harassment under a federal civil-rights law based on litigation in Maryland state courts and their alleged failure to rule on his cases.
The court found that neither the defendant’s residence nor a substantial part of the events was connected to New York. Because the claims arose in Maryland, the court transferred the case to the U.S. District Court for the District of Maryland.
Judge Colleen McMahon also warned that further frivolous cases filed in this court could lead to restrictions on filing without paying fees in advance. The order closed the case, and the court denied fee-free appeal status because any appeal would not be taken in good faith.
The detailed version
- Jiggetts v. State of Maryland · No. 1:20-cv-04910
- Colleen McMahon
- July 7, 2020
Background
Alexander Jiggetts, appearing without a lawyer, brought claims under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government actors. He alleged discrimination and harassment connected to cases he had filed in Maryland state courts and claimed those courts had refused to issue rulings.
Venue analysis
The court applied 28 U.S.C. § 1391, the federal venue statute. That statute generally permits a civil case to proceed where a defendant resides, where a substantial part of the relevant events occurred, or, in limited circumstances, where a defendant is subject to the court’s authority.
The court concluded that venue was not proper in the Southern District of New York because Jiggetts did not allege that any defendant resided there or that a substantial part of the relevant events occurred there. The court determined that the claims arose in Maryland and that venue was proper in the District of Maryland. Under 28 U.S.C. § 1406(a), the court therefore transferred the action to the U.S. District Court for the District of Maryland.
Warning and other directives
The court noted that Jiggetts had previously filed several actions in the Southern District of New York concerning events in Maryland. It warned that further frivolous litigation in that court, including cases concerning events outside the district, could lead to an order barring him from filing new cases without paying filing fees in advance unless he first obtained permission.
The court stated that the transferee court would decide whether Jiggetts could proceed without prepaying fees. It directed the Clerk to mail the order to him, stated that no summons would issue from the Southern District of New York, and closed the case. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.
Disposition
Judge Colleen McMahon transferred the action to the District of Maryland for improper venue. The opinion did not decide the merits of Jiggetts’s discrimination or harassment claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.