Williams v. Hardin County Detention Center
- Laura Swain
- 1:24-cv-03226
- U.S. District Court · Southern District of New York
- 3
In Williams v. Hardin County Detention Center, Judge Swain transferred the action to Kentucky because New York was an improper venue.
Clifton Clinton Williams IV and the named defendants—Hardin County Detention Center, J. Lindblom, and E. Lewis—are affected because the action was transferred from the Southern District of New York to the Western District of Kentucky.
What happened
In Williams v. Hardin County Detention Center, Clifton Clinton Williams IV, representing himself, sued the Hardin County Detention Center, J. Lindblom, and E. Lewis. He alleged violations of federal constitutional rights and cited an alleged violation of “world court statute Article 13.”
The Southern District of New York ruled that venue was improper there because the defendants and events appeared connected to Hardin County, Kentucky, rather than New York. The court found that the Western District of Kentucky was a proper venue and transferred the action there instead of dismissing it.
Judge Laura Taylor Swain directed the Clerk to transfer the action, closed the case in the Southern District of New York, and stated that summonses would not issue from that court. She also denied permission to proceed without prepaying fees for any appeal, based on the court’s certification that an appeal would not be taken in good faith.
The detailed version
- Williams v. Hardin County Detention Center · No. 1:24-cv-03226
- Laura Swain
- May 10, 2024
Background
Clifton Clinton Williams IV brought this action without a lawyer and sought injunctive relief. He alleged that the Hardin County Detention Center, Hardin County Jailer J. Lindblom, and HCDC Sergeant E. Lewis violated his federal constitutional rights. He also asserted “violations of world court statu[t]e Article 13.” The opinion states that HCDC is located in Elizabethtown, Hardin County, Kentucky, and that the individual defendants appeared to be employed there.
Venue analysis
Venue is the legally proper location for a federal case. Under 28 U.S.C. § 1391(b), a case generally may be filed where a defendant resides, where a substantial part of the relevant events occurred, or, in limited circumstances, where a defendant is subject to the court’s personal jurisdiction.
The court stated that Williams did not allege where the other defendants resided. It concluded, however, that HCDC appeared to reside in Kentucky, so the Southern District of New York was not a proper venue under § 1391(b)(1). The court also found that Williams did not allege that the events supporting his claims occurred in New York. Instead, the events appeared to have occurred in Hardin County, Kentucky, including at HCDC. The court therefore concluded that the Western District of Kentucky was a proper venue under § 1391(b)(2).
Ruling
Under 28 U.S.C. § 1406(a), when a case is filed in the wrong venue, a court may dismiss it or, in the interest of justice, transfer it to a district where it could have been filed. The court transferred this action to the United States District Court for the Western District of Kentucky in the interest of justice.
The court directed the Clerk to make the transfer, stated that the action was closed in the Southern District of New York, and stated that summonses would not issue from that court. It left the question of whether Williams could proceed without prepaying fees to the transferee court. The court also certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for purposes of an appeal.
The order transferred the case based on venue and did not decide whether Williams’s constitutional or other claims were legally valid.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.