Jiggetts v. State of Maryland
- Colleen McMahon
- 1:17-cv-06595-CM
- 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 transferred case was no longer under this court’s jurisdiction.
Alexander Jiggetts’s motion to seal was denied, and the court restricted further filings under the closed case number. Any request to seal through this court would require action in the District of Maryland and a transfer back to this district.
What happened
In Jiggetts v. State of Maryland, the court had transferred the action to the United States District Court for the District of Maryland in 2017. More than five years later, Alexander Jiggetts asked the Southern District of New York to seal the action.
The court ruled that transferring a case removes the original court’s authority to act on it. Because Jiggetts waited more than five years to file the motion, the Southern District of New York could not consider it. The court said he would need to ask the District of Maryland to transfer the case back before this court could consider sealing it.
Judge Colleen McMahon denied the motion to seal for lack of jurisdiction. The clerk was directed not to accept further filings from Jiggetts under the closed case number, except filings directed to the U.S. Court of Appeals for 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-06595-CM
- Colleen McMahon
- May 24, 2023
Background
By order dated August 31, 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, more than five years after the transfer, Alexander Jiggetts filed a motion to seal the action.
Jurisdiction over the motion
The court explained that transferring a case removes the transferring court’s jurisdiction—the legal authority to rule on matters in the case. The transferring court retains jurisdiction to review the transfer only when the party seeking review acts to stay the transfer before the case papers reach the clerk of the receiving court. Jiggetts did not seek review until more than five years after the transfer. The court therefore concluded that it lacked jurisdiction to consider his motion to seal.
The court stated that, if Jiggetts seeks to seal the action through the Southern District of New York, 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 sealing motion.
Ruling and other directives
Judge Colleen McMahon denied Jiggetts’s motion to seal for lack of jurisdiction. The clerk was directed not to accept 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 also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.