Ramrattan v. The State of New York

Background

Jerry Ramrattan, who is incarcerated at Eastern New York Correctional Facility and is proceeding without a lawyer, filed claims under 42 U.S.C. § 1983, the Americans with Disabilities Act, Section 504 of the Rehabilitation Act of 1973, and state law. He sued the State of New York and three employees of the New York State Department of Corrections and Community Supervision who work at the facility. The complaint concerns events at that facility.

Venue and Transfer

Venue is the federal district where a case may properly be litigated. Under 28 U.S.C. § 1391, venue may generally be proper where a defendant resides or where a substantial part of the events underlying the claims occurred. The court stated that the facility is in Ulster County, which lies in the Northern District of New York. Because the alleged events occurred outside the Southern District, venue did not appear proper there under the events-based provision.

The court noted that venue might still be proper in the Southern District under another provision because the State of New York arguably resides in both districts. The court also explained that, under 28 U.S.C. § 1404(a), a court may transfer a case for the convenience of the parties and witnesses and in the interest of justice, even on its own initiative. Relevant considerations included the location of the events, witnesses, documents, and evidence.

The court concluded that transfer was appropriate because the underlying events occurred at Eastern New York Correctional Facility, where Ramrattan is incarcerated and the individual defendants work, and where relevant witnesses and documents were likely located. It therefore found that the totality of the circumstances favored transfer to the Northern District of New York.

Disposition

The Clerk was directed to transfer the action to the United States District Court for the Northern District of New York. The order states that the transferee court will decide whether Ramrattan may proceed without prepaying fees. The Southern District court directed that no summons issue from that court and stated that the order closes the case there. It also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.

The court’s footnote observed that Ramrattan’s § 1983 claims against the State of New York were likely barred by the constitutional protection against certain suits against states in federal court, while his claims under the Americans with Disabilities Act might not be barred. The court did not resolve those issues or the merits of Ramrattan’s claims.