Goodall v. New York State Department of Corrections and Community Supervision
9:19-cv-01359
N.D.N.Y.Oct 1, 2019Background
- Plaintiff Shaun Goodall (pro se, later retained counsel) sued DOCCS, its Commissioner and Assistant Commissioner, and nine DOCCS/Greene Correctional Facility employees under Title II of the ADA and New York Human Rights Law.
- Complaint filed in E.D.N.Y.; events giving rise to the claims occurred at Greene Correctional Facility in the Northern District of New York.
- The court issued orders to show cause regarding transfer; parties briefed whether the case should be transferred under 28 U.S.C. § 1404(a).
- Court found venue would be proper in the Northern District because a substantial part of the events occurred there and several defendants reside there.
- Court weighed § 1404(a) factors: plaintiff’s forum choice, convenience of parties/witnesses, location of documents, and locus of operative facts; it found most witnesses and proof were in the Northern District and that E.D.N.Y. subpoena power (100-mile limit) would be insufficient.
- Plaintiff’s claims of hardship (residence in Suffolk County, indigence, mental disability) were insufficient to overcome the convenience and justice factors favoring transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the action "might have been brought" in the Northern District | Implicitly contested but didn’t dispute connection; argued forum selection should remain | Venue proper in Northern District because events and many defendants are located there | Northern District is a proper venue under § 1391 |
| Whether the court may transfer sua sponte under § 1404(a) | Court misplaces burden by asking plaintiff to show why not transferred absent a defendant motion | Courts may transfer sua sponte and both parties were given opportunity to be heard | Court may transfer sua sponte and considered parties’ submissions |
| Weight of plaintiff’s chosen forum | Goodall argued his Brooklyn forum choice and residence merit retention | Forum weight diminished because operative facts lack material connection to E.D.N.Y. | Plaintiff’s forum choice entitled to little weight given minimal ties to this District |
| Convenience and interests of justice (witnesses, documents, subpoena power, hardship) | Transfer merely shifts inconvenience to plaintiff; his residence, indigence, and disability make transfer burdensome | Defendants/witnesses and most proof are in Northern District; E.D.N.Y. subpoena range inadequate; defendants would be more inconvenienced if case stayed in E.D.N.Y. | Transfer to Northern District warranted under § 1404(a) for convenience of parties/witnesses and interests of justice |
Key Cases Cited
- Ferens v. John Deere Co., 494 U.S. 516 (1990) (federal courts may transfer actions sua sponte under § 1404)
- Haskel v. FPR Registry, Inc., 862 F. Supp. 909 (E.D.N.Y. 1994) (parties should be given opportunity to be heard before sua sponte transfer)
- Lead Indus. Ass'n v. Occupational Safety & Health Admin., 610 F.2d 70 (2d Cir. 1979) (discussing court practice on venue and transfer analysis)
- N.Y. Marine & Gen. Ins. Co. v. Lafarge N. Am., Inc., 599 F.3d 102 (2d Cir. 2010) (factors for transfer and analysis of convenience/justice under § 1404)