Valles v. Attorney General of the United States

Background

Andrew Valles, who was incarcerated at the California Institution for Men in Chino, California, filed this action without a lawyer. He sued the Attorneys General of the United States, California, and Utah in their official capacities. The opinion says he appeared to challenge his alleged retroactive designation under federal law and alleged requirement to register as a sex offender. He sought injunctive relief, meaning a court order requiring or prohibiting certain conduct. The court understood the complaint to assert claims under 42 U.S.C. § 1983, a civil-rights statute, and Bivens, a legal theory allowing certain claims against federal officials; it also understood the complaint to assert possible claims under the Administrative Procedure Act.

Venue and Transfer Analysis

Venue is the legally proper location for a case. The court explained that the federal venue statutes allow these types of claims in districts where defendants reside, where a substantial part of the relevant events occurred, or, in some circumstances, where the plaintiff resides. Valles did not allege that any defendant resided in New York State. He alleged that relevant events occurred in Utah in July 2006, in New York between August and December 2019, and at the California prison in March 2020. He also alleged that events would occur again at that prison. For purposes of the order, the court assumed that his reference to New York meant Manhattan.

The court concluded that the Southern District of New York, the District of Utah, and the Central District of California appeared to be proper venues for all of Valles’s claims. It also noted that New York might be a proper venue for his Administrative Procedure Act claims because he appeared to allege that he resided in New York City and the case did not involve real property.

Under 28 U.S.C. § 1404(a), a court may transfer a case to another proper district for the convenience of the parties and witnesses and in the interest of justice. The court found transfer appropriate because the most recent and future alleged events concerned the California prison, where Valles was incarcerated, and relevant documents were likely to be located in the Central District of California. The court therefore found that district to be the more convenient forum.

Disposition

The court transferred the action to the United States District Court for the Central District of California. It directed the clerk to carry out the transfer, stated that the transferee court would decide whether Valles could proceed without paying filing fees, and ordered that no summons issue from the Southern District of New York. The order closed the action in that court. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.