Stackhouse v. John Doe

Background

Carlos Stackhouse, who was incarcerated at Upstate Correctional Facility, brought this self-represented federal civil-rights action. He alleged that four unidentified correction officers used excessive force against him while he was confined at Wende Correctional Facility. The opinion identifies the officers as employees of the New York State Department of Corrections and Community Supervision.

Venue and Transfer

The court explained that federal law permits a civil action to proceed in certain districts, including a district where a substantial part of the events occurred. Wende is in Alden, Erie County, New York, which lies in the Western District of New York. Because Stackhouse alleged that the events occurred there, venue was proper in that district under the events-based venue rule, even though the opinion said it was unclear where the defendants resided.

The court also considered transfer under 28 U.S.C. § 1404(a), which allows a court to move a case to another proper federal district for the convenience of the parties and witnesses and in the interest of justice. It found transfer appropriate because the underlying events occurred at Wende and relevant witnesses and documents were reasonably expected to be there. The court also noted that Stackhouse did not reside in the Southern District of New York and that the operative events did not occur there.

Disposition

The court ordered the Clerk of Court to transfer the action to the United States District Court for the Western District of New York. It stated that the transferee court would decide whether Stackhouse could continue without prepaying fees. The Southern District court ordered that a summons not issue from that court and closed the case there.

The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not decide the merits of Stackhouse’s excessive-force allegations.