Janczuk v. United States of America
- Laura Swain
- 1:24-cv-02150
- U.S. District Court · Southern District of New York
- 3
In Janczuk v. United States, Judge Swain transferred the detention-related case to the Eastern District of New York for convenience.
Weronika Janczuk and the defendants named in the action; the case was moved from the Southern District of New York to the Eastern District of New York, without a ruling on the underlying retainer-access allegations.
What happened
In Janczuk v. United States of America (USA), Weronika Janczuk, representing herself, claimed that defendants denied her access to Invisalign retainers while she was detained at the Metropolitan Detention Center.
The court said the alleged events occurred at the detention center in Kings County, within the Eastern District of New York, and that the relevant documents were likely there. Because Janczuk resides in Queens County, the Eastern District also appeared more convenient.
The court transferred the action to the Eastern District of New York under the federal venue-transfer law. Judge Laura Taylor Swain also closed the case in the Southern District, directed that no summons issue there, left any decision about proceeding without prepaying fees to the receiving court, and denied fee-free status for an appeal.
The detailed version
- Janczuk v. United States of America · No. 1:24-cv-02150
- Laura Swain
- Apr. 12, 2024
Background
Weronika Janczuk, who represents herself and resides in Queens County, New York, sued the United States of America (USA), the Judicial & Personnel Teams at the USA Courthouse Federal (SDNY), Federal Defenders of New York (FDNY), Sylvie Levine, and the Brooklyn Metropolitan Detention Center (MDC). She alleged that the defendants denied her access to Invisalign retainers during her detention at the MDC.
Venue analysis
The court explained that federal law generally permits a civil action to proceed 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 alleged events occurred at the MDC in Kings County, which is in the Eastern District of New York. The court said it did not know where the individual defendants resided, so it could not determine whether venue was proper under the defendant-residence provision. Even assuming venue was proper in the Southern District of New York, venue was also proper in the Eastern District because the events occurred there.
The court further applied the federal law allowing transfer to another proper district for the convenience of the parties and witnesses and in the interest of justice. It found that the events occurred at the MDC, where the relevant documents could reasonably be expected to be located, and that Janczuk currently resides in Queens County. The Eastern District therefore appeared to be the more convenient forum.
Ruling
The court transferred the action to the United States District Court for the Eastern District of New York. The Clerk was directed to make the transfer. The court said the receiving court would decide whether Janczuk could continue without prepaying fees, and it directed that no summons issue from the Southern District. The order closed the case in that court. The court also certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. Judge Laura Taylor Swain signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.