Jaye v. Knuckles, Komosinski & Manfro, LLP
- Laura Swain
- 1:21-cv-03435
- U.S. District Court · Southern District of New York
- 2
In Jaye v. Knuckles, Judge Swain transferred the case to New Jersey because venue was improper in New York.
Chris Ann Jaye and the approximately 97 defendants; the case was moved from the Southern District of New York to the District of New Jersey.
What happened
In Jaye v. Knuckles, Chris Ann Jaye, representing herself, sued about 97 defendants under federal and New Jersey law. She alleged that the events and court proceedings involved in her claims occurred in New Jersey.
The court explained that venue—the proper federal court location for a case—was not proper in New York. Although Jaye alleged that some law firms and a bank had New York offices, she did not allege that all defendants lived in New York or that a substantial part of the events occurred there.
Judge Swain ordered the case transferred to the U.S. District Court for the District of New Jersey. The court terminated all pending motions and closed the case in the Southern District of New York; it also denied permission to appeal without paying fees.
The detailed version
- Jaye v. Knuckles, Komosinski & Manfro, LLP · No. 1:21-cv-03435
- Laura Swain
- May 5, 2021
Background
Chris Ann Jaye filed this action without a lawyer against approximately 97 defendants. She alleged violations of federal and New Jersey state law. The opinion states that the claims concerned events and court proceedings that occurred in New Jersey. Jaye alleged that several defendant law firms and a defendant bank had offices in New York, but the opinion states that most of the defendants appeared to reside in New Jersey.
Venue Analysis
Venue is the proper federal judicial district where a civil action may be brought. Under 28 U.S.C. § 1391(b), venue generally may be proper where all defendants reside, where a substantial part of the events occurred, or, in limited circumstances, where a defendant is subject to the court’s personal jurisdiction. The court found that venue was not proper in the Southern District of New York because Jaye did not allege that all defendants resided in New York or that a substantial part of the events or omissions underlying her claims occurred there.
The court determined that Jaye’s claims arose in New Jersey and that venue therefore lay in the District of New Jersey. It transferred the action under 28 U.S.C. § 1406(a), which permits transfer when venue is improper.
Disposition
The court directed the Clerk to transfer the action to the U.S. District Court for the District of New Jersey and to mail Jaye a copy of the order. Whether summonses would be issued was left to the discretion of the transferee court. The court terminated all pending motions and stated that the order closed the case in the Southern District of New York. The court also certified that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees. Judge Laura Taylor Swain signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.