Pakala v. U.S. District Court Judge, 2:23-cv-00577

Pro se plaintiff John Pakala, incarcerated in Clark County Detention Center, filed a civil-rights complaint invoking 42 U.S.C. § 1983, Bivens, and/or 28 U.S.C. § 2255 because he was unsure which remedy applied.
Pakala alleges he was originally convicted and sentenced in the Western District of Tennessee, overserved his sentence, was later rearrested by mistake, and challenges sentence credits and supervised-release handling.
Defendants named include a Doe U.S. District Judge (Memphis), a Doe federal prosecutor (Memphis), U.S. Marshals (Riverside, CA), a Doe warden (Adelanto, CA), and a federal public defender (Memphis).
Pakala did not submit an application to proceed in forma pauperis and did not pay the $402 filing fee.
Pakala’s only contacts with Nevada are traveling home to Las Vegas after release and a brief stay at the Nevada Southern Detention Center in Pahrump.
The court found Nevada an improper venue and ordered transfer of the case to the U.S. District Court for the Western District of Tennessee (Memphis); the court offered no opinion on the merits or the filing-fee issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proper venue	Pakala filed in Nevada without asserting strong ties elsewhere	No briefing from defendants on venue	Nevada is not proper venue; transfer warranted
Appropriate forum	Pakala invoked multiple remedies (§ 1983, Bivens, § 2255) and filed where he is detained	Defendants did not contest, but claims arise from events connected to Tennessee	Case transferred to Western District of Tennessee where defendants and underlying conviction are located
Transfer vs dismissal	Pakala sought to proceed in forum he chose	Court may transfer under 28 U.S.C. § 1406 when filed in wrong district	Court transferred case rather than dismissing
Filing fee / IFP	Pakala did not pay fee or file IFP application	Court noted omission but did not resolve fee question	Court declined to rule on fee/IFP and left that for the receiving court

Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971) (recognizes a cause of action for damages against federal officers for constitutional violations)