Jean-Baptiste v. United State Department of Justice

Background

Harold Jean-Baptiste brought this action without a lawyer against the United States Department of Justice, Merrick B. Garland, the Federal Bureau of Investigation, Christopher Wray, and Damian Williams. He asserted claims under 42 U.S.C. §§ 1983, 1985, and 1986, as well as various criminal statutes. His complaint also described efforts to obtain documents under the Freedom of Information Act, or FOIA.

The opinion states that Jean-Baptiste resides in Rosedale, Queens County, New York. He alleged that the defendants caused him to become sick at a Dunkin Donuts restaurant in Huntington Station, Suffolk County, and interfered with his medical care at Long Island Jewish Hospital in Valley Stream, Nassau County. Both counties are in the Eastern District of New York.

Venue analysis

For the non-FOIA claims, the court applied the general federal venue statute. It found that the allegations showed that all events giving rise to those claims occurred outside the Southern District of New York. The court also found that venue was not proper there under the rule concerning defendants’ residences because the defendants did not all reside in New York, based on the addresses provided in the complaint.

The court explained that venue for FOIA claims may be proper where the complainant resides, where the agency records are located, or in the District of Columbia. It concluded that the Eastern District of New York was a proper venue for any FOIA claims because Jean-Baptiste resides there. The opinion states that he had also filed other federal lawsuits related to the FOIA requests, but it does not decide those cases here.

Disposition

Under 28 U.S.C. § 1406, a court may transfer a case filed in the wrong venue when transfer is in the interest of justice. The court concluded that venue lay in the Eastern District of New York for both the non-FOIA and possible FOIA claims. It therefore transferred the action to the United States District Court for the Eastern District of New York. The Clerk was directed to complete the transfer, and the order states that the Southern District case was closed.

The court left the question of whether summonses should issue to the transferee court. It also certified that any appeal would not be taken in good faith and denied permission to appeal without paying court fees. The order did not decide the merits of Jean-Baptiste’s underlying claims.