Ahmad v. State of New York City

Background

Ahmad, who was detained at the Otis Bantum Correctional Center on Rikers Island and represented himself, brought an action under 42 U.S.C. § 1983, a federal law allowing claims for violations of constitutional rights by state or local officials. He alleged that the defendants violated his rights in connection with a November 2020 arrest in Kings County and criminal proceedings in the Kings County Supreme Criminal Court.

The caption listed the defendants as “State of New York City” and “Police Department 69th Precinct.” The court understood the latter to refer to the New York City Police Department’s 69th Precinct. Ahmad also named Detective Nicholas Gigante, Officers Angela Crenshaw and Marisa Louis-Jean, and an unnamed detective. He alleged that the individual defendants worked at the 69th Precinct in Brooklyn, Kings County.

Venue analysis

Venue is the federal district where a case may properly be heard. The court explained that a civil action may generally be filed where a defendant resides, where a substantial part of the events occurred, or, in some circumstances, where a defendant is subject to the court’s authority.

The court stated that Kings County is in the Eastern District of New York. Although venue might also have been proper in the Southern District of New York because the City of New York is considered a resident of both districts and the individual defendants appeared to reside in New York State, venue was proper in the Eastern District because the events underlying the claims occurred in Kings County.

The court then applied 28 U.S.C. § 1404(a), which allows a court to transfer a case to another proper district for the convenience of the parties and witnesses and in the interest of justice. It concluded that transfer was appropriate because the underlying events occurred in Kings County, the individual defendants worked there, and relevant documents and witnesses could reasonably be expected to be there.

Ruling

The court ordered the Clerk of Court to transfer the action to the United States District Court for the Eastern District of New York. The order did not decide the merits of Ahmad’s civil-rights claims. It stated that the transferee court would decide whether Ahmad could continue without prepaying filing fees. The Southern District court also directed that no summons issue from that court and stated that the order closed the case there.

The court certified that any appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The order was signed by Chief United States District Judge Laura Taylor Swain.