Quiroz v. UR Medicine St. James Hospital
- Laura Swain
- 1:23-cv-00453
- U.S. District Court · Southern District of New York
- 3
In Quiroz v. UR Medicine St. James Hospital, Chief Judge Swain transferred the case to the Western District of New York because venue was improper in the Southern District.
Nicole L. Quiroz’s case was transferred from the Southern District of New York to the Western District of New York. The transfer concerns venue and did not decide the merits of her claims against UR Medicine St. James Hospital.
What happened
In Quiroz v. UR Medicine St. James Hospital, Nicole L. Quiroz, representing herself, alleged that the hospital violated her rights during a December 2022 emergency-room incident in Steuben County, New York.
The court ruled that the Southern District of New York was the wrong federal court because the hospital and the events involved were in Steuben County. It transferred the case to the Western District of New York, where venue was proper, rather than dismissing it.
Chief Judge Laura Taylor Swain closed the case in the Southern District, directed the clerk to transfer it, and left any decision about allowing Quiroz to proceed without prepaying fees to the receiving court. The court also denied fee-free status for an appeal and said a summons would not issue from the Southern District.
The detailed version
- Quiroz v. UR Medicine St. James Hospital · No. 1:23-cv-00453
- Laura Swain
- Jan. 23, 2023
Background
Nicole L. Quiroz, who resides in Steuben County, New York, brought the action without a lawyer against UR Medicine St. James Hospital. She alleged that the defendant violated her rights during an incident in December 2022 in the defendant’s emergency room, which is located in Hornell, Steuben County, New York. The opinion does not describe the underlying alleged violations.
Venue analysis
Venue is the legally proper federal district for a case. The court explained that federal law generally permits a civil action to be filed where the defendant resides, where a substantial part of the events occurred, or, in limited circumstances, where the defendant is subject to the court’s authority. The court concluded from the complaint that venue was not proper in the Southern District of New York because the defendant was located in Steuben County and the events underlying the claims occurred there.
Steuben County is within the Western District of New York. The court therefore found that venue was proper in the Western District under the federal venue statute.
Ruling and effect
Under 28 U.S.C. § 1406, a court may transfer a case filed in the wrong venue when transferring it serves the interests of justice. The court transferred the action to the United States District Court for the Western District of New York. The clerk was directed to make the transfer, and the Southern District case was closed. The order did not decide whether Quiroz’s underlying claims were legally valid.
The court stated that the transferee court would decide whether Quiroz could proceed without prepaying filing fees. It also directed that no summons issue from the Southern District and certified that an appeal would not be taken in good faith, denying fee-free status for purposes of an appeal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.