Neiyerver Adrián Leon Rengel v. United States

Summary

The District Court for the District of Columbia held that venue was improper in an FTCA action brought by Neiyerver Adrián Leon Rengel concerning his detention and removal to El Salvador. The court concluded that the operative acts and omissions occurred in Texas, denied the plaintiff’s request for venue-related discovery, and transferred the case to the Southern District of Texas. The court’s opinion was issued per curiam by Chief Judge James E. Boasberg on August 3, 2026.

Holdings

1. Venue was improper in the District of Columbia because Plaintiff resided in Venezuela and the substantial acts with operative significance underlying his claims occurred in Texas, San Salvador, or in transit between Texas and El Salvador, rather than in Washington, D.C.
2. Venue-related discovery was unwarranted because Plaintiff did not show that discovery would produce new, relevant information capable of changing the conclusion that the complained-of acts occurred outside the District of Columbia.
3. The case was transferred to the Southern District of Texas in the interest of justice rather than dismissed.

Questions Presented

1. Whether venue for Plaintiff's FTCA claims was proper in the District of Columbia because federal officials there designed, directed, or supervised the challenged immigration actions.
2. Whether Plaintiff was entitled to venue-related discovery concerning the conduct and intent of federal officials in the District of Columbia.
3. Whether the case should be dismissed or transferred under 28 U.S.C. § 1406(a) after the court determined that venue was improper in the District of Columbia.

Disposition

remanded