Coffer v. Crayton

Summary

The United States District Court for the Eastern District of California ordered the transfer of Jonathan Christopher Coffer’s 42 U.S.C. § 1983 action to the Northern District of California. The court concluded that none of the defendants resided in the Eastern District and that the claim arose in Monterey County, making venue proper in the Northern District under 28 U.S.C. §§ 1391(b) and 1406(a).

Holdings

1. Venue was improper in the Eastern District of California because none of the defendants resided there and the claim arose in Monterey County, which is in the Northern District of California.
2. When a complaint is filed in the wrong federal district, the court may transfer it to the proper district in the interest of justice under 28 U.S.C. § 1406(a); here, transfer to the Northern District of California was appropriate.

Questions Presented

1. Whether venue was proper in the Eastern District of California under 28 U.S.C. § 1391(b).
2. Whether the action should be transferred to the Northern District of California under 28 U.S.C. § 1406(a) because it was filed in the wrong district.

Disposition

remanded