Hadassah Feinberg v. Ferdinand Cintron, Jr., 24-1794

Hadassah Feinberg filed a civil action and requested to proceed in forma pauperis (without paying court fees) in the United States District Court for the District of Maryland.
The district court denied her in forma pauperis motion and gave her 21 days to pay the required filing fee.
Before the 21 days elapsed, the court determined that venue was improper and transferred the case to the Middle District of Pennsylvania.
Feinberg appealed both the district court’s denial of in forma pauperis and the venue transfer order.
After transfer, the Pennsylvania court also denied in forma pauperis, gave another deadline, and dismissed the action for failure to comply.
The Court of Appeals reviewed whether it had jurisdiction over the appeal given these procedural developments.

Issue	Feinberg's Argument	Defendant's Argument	Held
Appealability of venue transfer	Should be appealable	Not a final/interlocutory order	Not appealable; court lacks jurisdiction
Denial of in forma pauperis status (MD Dist. Ct.)	Should be reversed	Issue is moot after transfer	Moot; appeal is advisory, no jurisdiction
Jurisdiction over transferred, closed case	Claims can still be heard	No longer pending, action moot	No jurisdiction; appeal dismissed
Motion to redact documents	Should be granted	Not addressed	Denied

Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541 (U.S. 1949) (defining collateral order doctrine and appealability)
TechnoSteel, LLC v. Beers Constr. Co., 271 F.3d 151 (4th Cir. 2001) (appeals court generally cannot review transfer orders after a case file is moved out of the circuit)
Roberts v. U.S. Dist. Ct. for the N. Dist. of Cal., 339 U.S. 844 (U.S. 1950) (denial of in forma pauperis is ordinarily appealable)
Holloway v. City of Va. Beach, 42 F.4th 266 (4th Cir. 2022) (mootness deprives courts of jurisdiction)
Norfolk S. Ry. Co. v. City of Alexandria, 608 F.3d 150 (4th Cir. 2010) (no legally cognizable interest if practical effect absent)