Walton v. JP Morgan Chase N.A.

Background

On March 27, 2024, the court ordered Deborah Walton, who was proceeding without counsel, to show cause—explain why the court should not take certain actions—regarding two issues: transferring the case to the United States District Court for the Southern District of Indiana and imposing a filing injunction, meaning a restriction on filing future lawsuits in the district. Walton submitted responses.

Transfer

The court concluded that transfer was warranted under 28 U.S.C. § 1404(a). That statute permits transfer for the convenience of the parties and witnesses and in the interest of justice. The court found that all relevant events occurred in the Southern District of Indiana. It also found that Walton was seeking to file in the Southern District of New York to evade a filing ban imposed by the Seventh Circuit. The court stated that any challenge to that ban should be made in the Seventh Circuit rather than by filing around it in New York.

Filing Injunction

The court declined to impose a filing injunction in the Southern District of New York at this time. Applying the relevant factors, it concluded that Walton had not yet abused the judicial process in that district enough to justify an injunction. The court reasoned that the Seventh Circuit’s filing ban, together with the likelihood that the case would be transferred to that circuit, would probably deter additional related lawsuits in New York. It added that a filing injunction might become appropriate if that deterrent proved insufficient.

Disposition

Judge Jesse M. Furman ordered the clerk to transfer the case to the United States District Court for the Southern District of Indiana and to close the case in the Southern District of New York. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied Walton permission to appeal without paying filing fees. The opinion does not state the claims’ underlying legal merits.