Broadnax v. State Controller's Office (CA), et al.

Summary

The United States District Court for the Northern District of California ordered transfer of this pro se civil rights action to the Eastern District of California for improper venue. The court concluded that the relevant events and all parties were located within the Eastern District of California, and held that a magistrate judge had authority to order the non-dispositive transfer.

Holdings

1. Venue was improper in the Northern District of California because the plaintiff, the defendants, and the events giving rise to the claims were located in the Eastern District of California.
2. A magistrate judge had authority to order the transfer because the transfer was non-dispositive and did not dispose of claims or defenses or terminate the action within the federal court system.

Questions Presented

1. Whether venue was proper in the Northern District of California or instead lay in the Eastern District of California under 28 U.S.C. § 1391(b).
2. Whether a magistrate judge could order transfer for improper venue before defendants had been served or appeared.

Disposition

remanded