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Rankin v. The City of New York
1:25-cv-06493
S.D.N.Y.
Aug 12, 2025
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Background

  • Adora Rankin filed a pro se action under 42 U.S.C. § 1983, alleging violations of her rights by the City of New York and several NYPD officers.
  • The alleged incident occurred at her residence in Jamaica, Queens County, New York.
  • The case was initially filed in the Southern District of New York.
  • Defendants include specific named NYPD officers (Gatto, Iacono, Marinaro) and two unnamed (John and Jane Doe) officers, as well as the City of New York.
  • Rankin provided a virtual office address in Manhattan, but alleges residence in Queens.
  • The court needed to determine proper venue and whether a transfer to the Eastern District of New York (covering Queens) was appropriate.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Proper Venue Actions violated rights in Queens No argument stated Venue proper in both SDNY and EDNY, but EDNY is more appropriate.
Convenience of Parties N/A N/A EDNY is more convenient for parties and witnesses.
Locus of Operative Facts Incident occurred in Queens N/A Queens (EDNY) is the locus of operative facts.
Transfer Appropriateness N/A N/A Case transferred to EDNY under § 1404(a).

Key Cases Cited

  • D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d Cir. 2006) (district courts have broad discretion regarding convenience and fairness of venue transfers)
  • N.Y. Marine and Gen. Ins. Co. v. LaFarge No. Am., Inc., 599 F.3d 102 (2d Cir. 2010) (factors for considering motions to transfer venue)
Read the full case

Case Details

Case Name: Rankin v. The City of New York
Court Name: District Court, S.D. New York
Date Published: Aug 12, 2025
Citation: 1:25-cv-06493
Docket Number: 1:25-cv-06493
Court Abbreviation: S.D.N.Y.