Jiggetts v. State of Maryland
- Colleen McMahon
- 1:17-cv-06255
- U.S. District Court · Southern District of New York
- 2
In Jiggetts v. State of Maryland, Judge McMahon denied Alexander Jiggetts’s motion to seal because the transfer left this court without jurisdiction.
Alexander Jiggetts’s motion to seal was denied, and further submissions under the closed Southern District of New York case number will not be accepted except papers directed to the Second Circuit.
What happened
In Jiggetts v. State of Maryland, the Southern District of New York had transferred the case to the District of Maryland in August 2017. Alexander Jiggetts filed a motion to seal the action in January 2023, more than five years later.
The court explained that a court transferring a case generally loses authority over it once the case is transferred. Because Jiggetts waited more than five years to file his motion, the New York court could not decide it.
Judge McMahon denied the motion to seal for lack of jurisdiction. The clerk was directed not to accept further filings under the closed case number, except papers directed to the Second Circuit. The court also denied permission to appeal without paying filing fees, finding that an appeal would not be taken in good faith.
The detailed version
- Jiggetts v. State of Maryland · No. 1:17-cv-06255
- Colleen McMahon
- May 23, 2023
Background
On August 18, 2017, the Southern District of New York transferred this action to the United States District Court for the District of Maryland. On January 30, 2023, Alexander Jiggetts moved to seal the action.
Reasoning
The court held that transferring a case divests the transferor court—the court that sent the case elsewhere—of jurisdiction, meaning authority to rule on the case or related motions. The transferor court retains jurisdiction to review the transfer only if the party seeking review acts to stay the transfer before the papers are received by the clerk of the transferee court. Because Jiggetts waited more than five years to file his motion, the Southern District of New York lacked jurisdiction to consider it.
The court stated that, if Jiggetts seeks to seal the action, he must move in the District of Maryland and ask that court to transfer the action back to the Southern District of New York for consideration of the motion.
Ruling
Judge McMahon denied Jiggetts’s motion to seal for want of jurisdiction. The clerk was directed not to accept any further submissions from Jiggetts under the closed case number, except papers directed to the United States Court of Appeals for the Second Circuit. The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees for purposes of that appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.