Statute Annotations › Federal › 28 U.S.C. § 1391

28 U.S.C. § 1391

Venue generally: the cases that interpreted this section

Jurisdiction
Federal
Case notes
8,639
Cited in passing
6,372
Citing cases indexed
23,910
Case dates
1949–2026
Screened through
2026-06-26
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

15,011 citing cases reviewed of 23,910 in the citation index: 8,639 interpreted the section (annotated below), 6,372 cited it only in passing. Cases filed after 2026-06-26 may not have been reviewed yet.

Have a situation under 28 U.S.C. § 1391?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Where the claim arose

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC)Hill v. Perez · filed 2021-01-13(b)(2)

In this case, the claim arose in Monterey County, which is in the Northern District of California. Therefore, plaintiffs claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Sams v. California Department of Corrections and Rehabilitation · filed 2021-03-22(b)

In this case, the claim arose in Riverside County, which is in the Central District of California. Therefore, plaintiffs claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where a substantial part of the events giving rise to a claim occurred.

Newson v. Atkins · filed 2021-09-23(b)

Moreover, Newson’s claim that he was denied medical care at the TTCC is wholly unrelated to the other claims asserted in this case and did not occur in this district. Therefore, the proper venue for that claim would be in the Nashville Division of the U.S. District Court for the Middle District of Tennessee. See 28 U.S.C. § 1391(b); see also 28 U.S.C. § 123(b)(1). Because Newson’s meager allegations fail to state a claim, however, the Court declines to sever and transfer that claim to the proper court.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a judicial district where the event giving rise to the claim occurred.

(PC) Hill v. Camacho · filed 2021-09-30(b)

Venue is proper because the event giving rise to the claim is alleged to have occurred in SVSP, which is located in this judicial district.
Read the full opinion on CourtListener →

Section 1391(b) places venue for a challenge to a conviction in the district where the conviction occurred.

(HC) Wright v. Warden · filed 2021-11-16(b)

The federal venue statute requires that a civil action, other than one based on diversity jurisdiction, be brought only in “(1) a judicial district where any defendant resides, if all defendants are residents of the State in which the district is located, (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of the property that is the subject of the action is situated, or (3) if there is no district in which an action may otherwise be brought as provided in this section, any judicial district in which any defendant is subject to the court’s personal jurisdiction with respect to such action.” 28 U.S.C. § 1391(b). ... In this case, the petitioner is challenging a conviction from Santa Clara County, which is in the Northern District of California. Therefore, the petition should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Baran v. Dodee County Detention Facility · filed 2021-11-18(b)

The federal venue statute provides that a civil action “may be brought in (1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located, (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated, or (3) if there is no district in which an action may otherwise be brought as provided in this action, any judicial district in which any defendant is subject to the court’s personal jurisdiction with respect to such action.” 28 U.S.C. § 1391(b). In this case, the claim arose in Dodge County, which is in the Western District of Wisconsin.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC)Frazer v. Diaz · filed 2021-12-20(b)(2)

Therefore, plaintiff’s claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where the defendants reside or where the claim arose; alleged conduct occurring entirely in another district does not establish venue in the chosen district.

Harris v. Santure · filed 2022-01-13(b)

Venue for Plaintiffs lawsuit is not proper in the Eastern District of Michigan, because Plaintiff has failed to allege that any acts, events, or omissions which form the basis of his lawsuit took place in this district.
Read the full opinion on CourtListener →

Section 1391(b) places venue in the district where a substantial part of the events giving rise to the claim occurred.

Rollings v. Trump · filed 2022-01-21(b)

In this case, the claim arose in Los Angeles County, which is in the Central District of ... California. Therefore, plaintiff’s claim should have been filed in the United States District Court ... for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action to be brought in a district where a substantial part of the events giving rise to the claim occurred.

(HC) Hornbeck v. Dept. of Corrections and Rehabilitation · filed 2022-04-27(b)

In this case, petitioner’s claims arose in Imperial County which is in the Southern District of California. Therefore, petitioner’s claims should have been filed in the United States District Court for the Southern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action in the district where a substantial part of the events giving rise to the claim occurred.

(HC)Robinson v. Atascadero State Hospital · filed 2022-09-19(b)

In this case, the claim arose in San Luis Obisbo County, which is in the Central District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391 permits venue in a district where the acts giving rise to the claims occurred.

Midland State Bank v. United States · filed 2022-09-30

Venue is proper because the acts giving rise to Midland’s claims occurred within this District. Stip. ¶ 4; 28 U.S.C. § 1391.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Darbouze v. Wiess · filed 2023-02-06(b)(2)

In this case, the claim arose in Los Angeles County, which is in the Central District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court ... for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Bolin v. Northern District Court · filed 2023-04-24(b)(2)

In this case, the claim arose in San Francisco County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Townsend v. Federal Express Headquarters · filed 2023-05-16(b)

Therefore, plaintiffs claim should have been filed in the United States District Court for the Western District of Tennessee.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

Ciccolelli v. Nationwide General Insurance Company · filed 2023-06-13(b)

In this case, the claim arose in Salt Lake County, which is in the District of Utah. Therefore, plaintiffs claim should have been filed in the United States District Court for the District of Utah.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Hall v. Barry · filed 2023-06-13(b)(2)

In this case, the claim arose in Marin County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court ... for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Baker v. County of Alameda · filed 2023-06-20(b)(2)

The federal venue statute provides that a civil action “may be brought in ... (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, ...” 28 U.S.C. § 1391(b). ... In this case, the claim arose in Alameda County, which is in the Northern District of California.
Read the full opinion on CourtListener →

A civil action may be brought in the district where a substantial part of the events giving rise to the claim occurred.

(PC) DePonte v. Bierman · filed 2023-07-25(b)(2)

In this case, the claim arose in Monterey County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court forthe Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Clayborne v. Palmdale Hosp. · filed 2023-07-31(b)(2)

In this case, the claim arose in Los Angeles County, which is in the Central District of California.
Read the full opinion on CourtListener →

Sections 1391(b)(2) and (e)(B) permit venue where a substantial part of the events giving rise to a claim occurred.

Anderson v. The Pentagon · filed 2023-10-04(b)(2), (e)(B)

Venue does not lie in this district under Section 1391(b) or (e).
Read the full opinion on CourtListener →

Section 1391(b) permits a damages claim about conditions of confinement in the district where the alleged conditions occurred.

Wells v. Ray · filed 2023-10-12(b)

To the extent Petitioner seeks monetary relief related to her alleged conditions of confinement, she may pursue such action in the Northern District of West Virginia where such action arose, but not here. See 28 U.S.C. § 1391(b).
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Gaines v. Greigore · filed 2023-11-28(b)(2)

In this case, the claim arose in Alameda County, which is in the Northern District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action to be filed in the district where a substantial part of the events giving rise to the claim occurred.

Busse v. State of California · filed 2023-11-29(b)(2)

In this case, the claim arose in San Bernardino County, which is in the Central District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Gaines v. Zhou · filed 2023-12-18(b)(2)

In this case, the claim arose in Alameda County, which is in the Northern District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a judicial district where a substantial part of the events giving rise to the claim occurred.

(PC) Coleman v. Garcia · filed 2023-12-27(b)

In this case, the claim arose in Monterey County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Hill v. Khana · filed 2024-01-03(b)

In this case, the claim arose in Napa County, which is in the Northern District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Jefferson v. Beam · filed 2024-03-19(b)(2)

In this case, the claim arose in Monterey County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Duckett v. Garcia · filed 2024-04-01(b)

Therefore, plaintiffs claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) places venue where the defendant resides or where the events giving rise to the claim occurred.

Ford v. Buchanan · filed 2024-04-05(b)

Venue for plaintiff’s lawsuit is not proper in the Eastern District of Michigan, because plaintiff has failed to allege that any of the acts, events, or omissions which form the basis of his lawsuit took place in this district.
Read the full opinion on CourtListener →

Under § 1391(b), venue is improper for claims arising from care outside the judicial district when no other basis for venue is shown.

Bassett v. Dearmon · filed 2024-06-06(b)

Venue is not proper here for those potential claims because the care at issue did not occur within this judicial district.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Eaves v. Betfair Interactive US, LLC · filed 2024-09-09(b)(2)

Venue appears to be proper, under Section 1391(b)(2), in the Western District of Pennsylvania, where Plaintiff’s claims arose. Accordingly, the Court transfers this action to the United States District Court for the Western District of Pennsylvania.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Hill v. Tom · filed 2024-09-25(b)(2)

In this case, the claim arose in Napa County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action to be brought in the district where a substantial part of the events giving rise to the claim occurred.

(PC)Goodlow v. Broomfield · filed 2024-10-01(b)(2)

In this case, the claim arose in Marin County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action to be filed in the judicial district where a substantial part of the events giving rise to the claim occurred.

(PC) Hill v. Ana · filed 2024-10-07(b)(2)

In this case, the claim arose in Napa County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Jones v. Electrics · filed 2024-10-16(b)

In this case, the claim arose in Alameda County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Jones v. Murphey · filed 2024-11-05(b)(2)

In this case, the claim arose in Humboldt County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action to be brought in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Rowe v. Gomez · filed 2024-11-21(b)(2)

In this case, the claim arose in Los Angeles County, which is in the Central District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Jones v. Macomber · filed 2024-12-04(b)(2)

In this case, the claim arose in Riverside County, which is in the Central District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action in a district where a substantial part of the events or omissions giving rise to the claim occurred.

(PC) Hill v. Ana · filed 2024-12-11(b)

In this case, the claim arose in Napa County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

A civil action may be brought in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Kern v. Patel · filed 2024-12-20(b)(2)

In this case, the claim arose in Del Norte County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Foust v. Ahadzia · filed 2025-01-21(b)(2)

In this case, the claim arose in Los Angeles County, which is in the Central District of California. Therefore, plaintiff's third amended complaint should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Kern v. Arriero-Goff · filed 2025-01-24(b)(2)

In this case, the claim arose in Del Norte County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action to be filed in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Arant v. Unknown · filed 2025-02-06(b)

Therefore, plaintiff's complaint should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Stevens v. SBMC · filed 2025-02-28(b)

In this case, the claim arose in Mendocino County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court ... for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Baggett v. Atascadero State Hospital · filed 2025-05-07(b)(2)

In this case, the claim arose in San Luis Obispo County, which is in the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

Trotter v. Whithney · filed 2025-05-30(b)(2)

Under 28 U.S.C. § 1391(b), a civil action of this type may be brought in: ... (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is subject of the action is situated; ... Here, plaintiff’s claims arise entirely from events which occurred during his incarceration in the Western District of Missouri.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where the breach giving rise to a contract claim occurred.

SIGNATURE ENERGY LLC v. CORPORATE AIR, LLC · filed 2025-07-10(b)(2)

Venue is also proper in this Court as the breach of the agreements occurred within the Western District of Pennsylvania.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action to be brought in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Hatten v. United States · filed 2025-07-25(b)

In this case, the claim arose in San Bernadino County, which is in the Central District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action to be brought in the district where a substantial part of the events giving rise to the claim occurred.

(PC) Latour v. A1 Towing · filed 2025-08-06(b)(2)

In this case, the claim arose in San Mateo County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Finley v. California Treatment Facility · filed 2025-08-06(b)

The federal venue statute provides that a civil action “may be brought in (1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located, (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated, or (3) if there is no district in which an action may otherwise be brought as provided in this action, any judicial district in which any defendant is subject to the court’s personal jurisdiction with respect to such action.” 28 U.S.C. § 1391(b). In this case, the claim arose in Monterey County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) provides no basis for venue in a district where the claim did not arise and no other basis for venue exists.

(PC) Vanleeuwen v. CDCR · filed 2025-08-11(b)

There does not appear to be any basis for venue in this court.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Vanleeuwen v. California Department of Corrections and Rehabilitation · filed 2025-08-11(b)

There does not appear to be any basis for venue in this court.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Bender · filed 2025-09-09(b)(2)

In this case, the claim arose in San Luis Obispo County, which is in the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Coffer · filed 2025-09-17(b)(2)

In this case, the claim arose in Monterey County, which is in the Northern District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in a district where a substantial part of the events giving rise to the claim occurred.

Gonzalez v. Samuel · filed 2025-09-29(b)(2)

In this case, the claim arose in San Luis Obispo County, which is in the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

Pido · filed 2025-10-16(b)(2)

In this case, the claim arose in San Luis Obispo County, which is in the Central District of California.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action to be brought in a district where a substantial part of the events giving rise to the claim occurred.

Jones v. Alameda County Juvenile Justice Center · filed 2025-10-21(b)

In this case, the claim arose in Alameda County, which is in the Northern District of California. Therefore, plaintiff's claim should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

CDCR · filed 2025-10-31(b)(2)

In this case, the claim arose in Del Norte County, which is in the Northern District of California. Therefore, plaintiff's claim cannot proceed in this court, but should have been filed in the United States District Court for the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits a civil action in the district where a substantial part of the events giving rise to the claim occurred.

(PC)Quintana · filed 2025-12-15(b)(2)

In this case, the claim arose in San Diego County, which is in the Southern District of California. ... Accordingly, IT IS HEREBY ORDERED that this matter is transferred to the United States District Court for the Southern District of California.
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in the district where a substantial part of the events giving rise to the claim occurred.

Duran · filed 2026-01-27(b)(2)

Therefore, plaintiff’s claim should have been filed in the United States District Court for the Southern District of California.
Read the full opinion on CourtListener →

Law changed since Pub. L. 101-650 (Dec. 1, 1990) replaced the single district where a claim arose with districts where a substantial part of the events or omissions occurred.

In a diversity action, venue is proper in a district where the claim arose.

Embree v. Cutter Biologics · filed 1991-02-14(a)

As the cause of action arose in Memphis, Tennessee, the defendant corporation resides in Tennessee, and most of the witnesses live in Tennessee, it is a venue in which the cause “might have been brought.”
Read the full opinion on CourtListener →

Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred, including where the plaintiff’s implantation surgery took place.

ROGERS v. ETHICON, INC. · filed 2019-12-23(b)(2)

Ms. Rogers’s action could have been brought in the Eastern District of Virginia and Ms. Monroe’s action in the Northern District of New York. ... The second basis of venue under Section 1391(b)(2) is the “judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated.”
Read the full opinion on CourtListener →

Section 1391(b) permits venue where a defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred.

Brown 712722 v. LeBarre · filed 2020-06-15(b)

The statute provides that a civil action may be brought in (1) a judicial district in which any defendant resides; or (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred. 28 U.S.C. 1391(b). ... The events giving rise to the complaint are also alleged to have occurred in Ionia County. Ionia County is located in the Western District of Michigan. 28 U.S.C. § 102(b). The facts in the complaint indicate that venue would be proper in the Western District rather than in the Eastern District.
Read the full opinion on CourtListener →

Section 1391(b) places a habeas petition challenging a conviction in the district where that conviction occurred.

(HC) Theus v. Phillips · filed 2023-02-10(b)

In this case, the petitioner is challenging a conviction from Los Angeles County, which is in the Central District of California. Therefore, the petition should have been filed in the United States District Court for the Central District of California.
Read the full opinion on CourtListener →

Service on federal officers

Section 1391(e)'s nationwide service of process does not establish personal jurisdiction over federal officials sued for damages in their individual capacities.

Vu v. Meese · filed 1991-01-08(e)

In reversing the Driver court’s reliance on the nationwide service of process in 28 U.S.C. § 1391(e) to establish personal jurisdiction over government officials sued in their individual capacities, the U.S. Supreme Court restricted the application of 28 U.S.C. § 1391(e) to instances where governmental officials were sued in their official capacity. Therefore, the fact that federal government officials enforce federal laws and policies on a nationwide basis is not sufficient in and of itself to maintain personal jurisdiction in a lawsuit which seeks money damages against those same governmental officials in their individual capacities. The governmental officials must have the requisite minimum contacts with the forum state for personal jurisdiction to exist.
Read the full opinion on CourtListener →

Section 1391(e) permits service on a federal officer even when the plaintiff also names a local, nonfederal agency as a defendant.

Powelton Civic Home Owners Ass'n Ex Rel. Hilburn Harbidge v. Department of Housing & Urban Development · filed 1968-04-22(e)

The defendants’ argument, though arguably supported by the literal language of Section 1391(e), is inconsistent with the apparent spirit and intent of the provision. ... The defendants’ construction of Section 1391(e) would resurrect the illogical procedural limitations which the provision sought to bury.
Read the full opinion on CourtListener →

Section 1391(e) permits service by certified mail on a federal officer outside the district while requiring compliance with the Federal Rules of Civil Procedure; absent proper service or waiver, the court lacks jurisdiction.

Smith v. Robert S. McNamara U. S. Secretary of Defense, Gilbert Esco Angle v. Robert S. McNamara U. S. Secreta · filed 1968-06-12(e)

Public law 87-748 (1962), 28 U.S.C. §§ 1361, 1391(e), which confers jurisdiction on the District Courts to entertain actions in the nature of mandamus against government officers ... provides for service of summons and complaint in accordance with the Federal Rules of Civil Procedure “except that delivery of the summons and complaint to [such] officer * * * may be made by certified mail [outside] the district in which the action is brought.” 28 U.S.C. § 1391(e). ... It follows that the court never acquired jurisdiction in Angle’s case and the action must be dismissed on that ground.
Read the full opinion on CourtListener →

Section 1391(e) does not authorize service outside the forum state when the suit includes a nonfederal defendant.

Benson v. City of Minneapolis · filed 1968-07-01(e)

28 U.S.C. § 1391(e) does not authorize extraterritorial service in the instant ease since each of the defendants is not a Federal defendant.
Read the full opinion on CourtListener →

Section 1391(e) authorizes nationwide service of process in civil actions against federal officers but does not extend habeas corpus jurisdiction.

Schlanger v. Seamans · filed 1971-05-17(e)

Although by 28 U. S. C. § 1391 (e) (1964 ed., Supp. V), Congress has provided for nationwide service of process in a “civil action in which each defendant is an officer or employee of the United States,” the legislative history of that section is barren of any indication that Congress extended habeas corpus jurisdiction. That section was enacted to broaden the venue of civil actions which could previously have been brought only in the District of Columbia. See H. R. Rep. No. 536, 87th Cong., 1st Sess., 1; S. Rep. No. 1992, 87th Cong., 2d Sess., 2. Though habeas corpus is technically “civil,” it is not automatically subject to all the rules governing ordinary civil actions. See Harris v. Nelson, 394 U. S. 286.
Read the full opinion on CourtListener →

Section 1391(e) permits certified mail service beyond the district to join indispensable federal officials after jurisdiction has attached.

Alvin G. Smith, and v. Capt. James M. Campbell, Commanding Officer, U. S. Naval Schools Command, Mare Island, Vallejo, C · filed 1971-12-01(e)

In order to obtain jurisdiction over indispensable federal officials who are outside the territorial jurisdiction of the district court, the court may utilize the provisions of 28 U.S.C. § 1391(e), which provides that process may be served by certified mail beyond the territorial limits of the district. ... However, the Court did not suggest that once jurisdiction to consider the merits of a habeas corpus petition is first properly established, § 1391(e) could not be used to join indispensable parties. ... Section 1391 may not be utilized to confer jurisdiction, but can be in order to effectuate jurisdiction once it has attached.
Read the full opinion on CourtListener →

Section 1391(e) permits extraterritorial service when the defendants subject to that requirement are beyond the forum's territorial limits.

Saipan Ex Rel. Guerrero v. United States Department of Interior · filed 1973-03-20(e)

The better rule, supported by virtually all courts which have considered this problem, is that the requirement refers only to defendants who are beyond the forum’s territorial limits.
Read the full opinion on CourtListener →

Section 1391(e) permits service beyond the forum state on a current federal officer sued for conduct in the course of official duties, but does not extend that service to former officers sued for damages.

Wu v. Keeney · filed 1974-10-17(e)

Accordingly the Court concludes that service of process on defendant Emerson was properly made pursuant to Rule 4(f) and section 1391(e). ... Nothing in the legislative history indicates that Congress intended to include past employees who are being sued for damages in the category of persons subject to extra-territorial service.
Read the full opinion on CourtListener →

Section 1391(e) permits service of process by certified mail in a suit against federal officials.

Crowley v. United States · filed 1975-02-19(e)

The Court finds this objection to be meritless, since 28 U.S.C. § 1391(e) provides for service of process by certified mail, which was accomplished here.
Read the full opinion on CourtListener →

Section 1391(e) permits service on former federal officers sued for actions taken under color of legal authority.

Lowenstein v. Rooney · filed 1975-07-31(e)

The actions complained of by the plaintiff clearly were committed “under color of legal authority.” To assert that because the defendants are no longer in government service the plaintiff may not utilize section 1391(e)—a section clearly intended to permit such actions —would, as plaintiff contends, defeat the purposes of the statute. If the defendants desire to invoke official immunity, they may do so directly. Since service was proper under section 1391(e), the motions of defendants Haldeman and Higby (motions 4 and 5) are denied.
Read the full opinion on CourtListener →

Section 1391(e) permits extraterritorial service on a federal officer even when the action also names nonfederal defendants.

Scott v. Parham · filed 1975-12-02(e)

While the literal language of § 1391(e) might be taken to mean that every defendant named in the action must be a federal officer or employee, this court holds that the better view is that the word “each” in the statute refers to each defendant who is outside the court’s jurisdiction and whose presence is sought by extraterritorial service.
Read the full opinion on CourtListener →

Section 1391(e) permits service on federal officers and agencies by a method prescribed in Federal Rule of Civil Procedure 4(d).

East Tennessee Research Corp. v. Tennessee Valley Authority · filed 1976-06-28(e)

It is not clear whether this question is governed by 28 U.S.C. § 1391(e) (1970), concerning service on “officers” and “agencies” of the United States, or by the more general Rule 4(e) of the Federal Rules of Civil Procedure. But that question need not be answered here, since both provisions allow service by the method prescribed in Rule 4(d) of the Federal Rules.
Read the full opinion on CourtListener →

Section 1391(e) permits service by certified mail beyond the district on a federal officer sued in an official capacity.

Thompson v. Kleppe · filed 1976-12-15(e)

Furthermore, the District Court of Hawaii has previously held that defendant Johnston is subject to process under 28 U.S.C. § 1391(e). ... Therefore, service of process by certified mail was proper.
Read the full opinion on CourtListener →

Section 1391(e)’s nationwide service of process does not make federal officials subject to habeas proceedings anywhere in the country regardless of their contacts with the court’s territorial jurisdiction.

Noll v. The People of the State of Nebraska · filed 1976-06-17(e)

The nationwide service of process upon federal officials authorized by 28 U.S.C. § 1391(e) has not subjected them to habeas proceedings anywhere in the country, regardless of contacts with the court’s territorial jurisdiction.
Read the full opinion on CourtListener →

Law changed since Stafford v. Briggs (Feb. 20, 1980) held that § 1391(e) does not govern personal-capacity damages suits against federal officers.

Section 1391(e) permits service beyond the district in personal damages suits against federal officers for acts taken under color of legal authority, and its use requires service on the United States under Rule 4(d)(5).

Lawrence v. Acree · filed 1978-08-23(e)

The Court interprets notes 15 and 18 in Relf v. Gasch and dicta found in note 58 of the Briggs opinion as indications that the Court of Appeals for the District of Columbia has determined that the provisions of 28 U.S.C. § 1391(e) and Fed.R.Civ.P. 4(d)(5) operate in tandem. Accordingly, the service provisions of Fed.R. Civ.P. 4(d)(5) are triggered by personal damage actions against federal officers for actions taken under color of legal authority.
Read the full opinion on CourtListener →

Section 1391(e) permits service on a federal officer by certified mail when the United States Attorney is also personally served.

STATE OF CAL. BY & THROUGH YOUNGER v. Blumenthal · filed 1978-10-03(e)

The file now indicates, however, that defendant was served by certified mail and that, in addition, the United States Attorney in Sacramento was personally served. Thus, service appears to have been sufficient. 28 U.S.C. § 1391(e); F.R.Civ.P. Rule 4(d)(4), (5).
Read the full opinion on CourtListener →

Section 1391(e)'s nationwide service and venue provisions do not apply to suits for money damages against federal officials in their individual capacities.

Johnson v. Carlson · filed 1983-10-20(e)

Under 28 U.S.C. § 1391(e) this form of service would be sufficient if these individuals were sued only in their official capacity. However, in Stafford v. Briggs, 444 U.S. 527, 100 S.Ct. 774, 63 L.Ed.2d 1 (1980), the Supreme Court held that the nationwide service of process and venue provisions of § 1391(e) do not apply to actions against federal officials for money damages. Since Courts have found service by certified mail to be insufficient when federal officials are being sued for damages in their individual capacity, service of process must be made in compliance with Texas law.
Read the full opinion on CourtListener →

Section 1391(e) permits service through the United States Attorney on a federal officer sued in an official capacity, but not one sued in an individual capacity.

Waller v. Butkovich · filed 1984-04-17(e)

The defendants have argued, convincingly, that such service is adequate only against a federal officer sued in his official capacity.
Read the full opinion on CourtListener →

Section 1391(e) allows extraterritorial mail service on federal employees only when they are sued in their official capacities.

Funches v. Wright · filed 1986-11-06(e)

Fed.R.Civ.P. 4(d)(5), 4(f), and 28 U.S.C. Sec. 1391(e) do allow extraterritorial mail service on a federal employee. Section 1391(e), however, limits service to federal employees sued in their official capacities.
Read the full opinion on CourtListener →

Section 1391(e) permits service by certified mail on a federal officer or agency but does not eliminate the separate requirement to serve the United States personally.

Dowdy v. Sullivan · filed 1991-02-22(e)

§ 1391(e) allows delivery of the summons and complaint to be made by certified mail to the “officer or agency.” This is consistent with Rule 4(d)(5), which allows for service of process by certified mail upon an officer or agency of the United States. Nothing in § 1391(e), however, contravenes the requirement in Rule 4(d)(4) and (5) to also serve the United States and service upon the United States requires personal service.
Read the full opinion on CourtListener →

Section 1391(e)(2) permits certified-mail delivery beyond the district court’s territorial limits only in suits against United States officers or employees.

Milbeck, Ryan-William v. George, Allison · filed 2024-05-02(e)(2)

Although plaintiff argues otherwise in reliance on 28 U.S. § ... 1391(e)(2), which allows for delivery by certified mail on defendants “beyond the territorial limits of” the district court where the action is brought, that statute applies only to lawsuits in which the defendant is an officer or employee of the United States. The statute is therefore not applicable here.
Read the full opinion on CourtListener →

Section 1391(e) does not authorize service on federal employees sued in their individual capacity.

Clymer v. Grzegorek · filed 1981-04-24(e)

The Supreme Court has held, however, that § 1391 does not provide a means of serving federal employees sued in their individual capacity.
Read the full opinion on CourtListener →

Venue for federal agency defendants

Section 1391(e)(1)(A) permits a suit against a federal agency in a district where a defendant resides.

Pouri v. United States Department of Homeland Security · filed 2026-05-30(e)(1)(A)

Under 28 U.S.C. § 1391(e)(1)(A), a plaintiff may bring a civil action against “an agency of the United States” or “an officer or employee” thereof “acting in his official capacity” “in any judicial district in which . . . a defendant in the action resides.” Plaintiff has named the Department of Homeland Security (“DHS”) as a Defendant and there is no dispute that DHS is located in the District of Columbia.
Read the full opinion on CourtListener →

In an action against a federal agency, venue is proper in a district where a substantial part of the events giving rise to the claim occurred.

Watts v. Department of Justice Office of the Inspector General · filed 2026-05-01(e)(1)(B)

Thus, under Section 1391(e)(1)(B), this court and the United States District Court for the Western District of Arkansas are proper venues for this action.
Read the full opinion on CourtListener →

Section 1391(e) does not establish venue based on the plaintiff’s residence when the Department of Justice is not named as a defendant.

English v. The United States Department of Justice · filed 2025-06-04(e)

Contrary to English’s objection, the Department of Justice is not named as a defendant, therefore venue in this action does not fall within the scope of § 1391(e).
Read the full opinion on CourtListener →

Section 1391(e)(1)(A) permits venue in a district where a federal agency resides; the Department of Justice can be considered a resident of every judicial district.

Reeves v. United States Department of Justice · filed 2025-05-14(e)(1)(A)

The United States Department of Justice, as a federal agency, can be considered a resident of every judicial district in the nation. Venue is therefore proper for this action under Section 1391(e)(1)(A) in every judicial district in the nation, including this District and the Eastern District of New York.
Read the full opinion on CourtListener →

Section 1391(e) governs venue for FMLA and constitutional claims against a federal agency based on the defendant’s residence, where substantial claim events occurred, or the plaintiff’s residence when no real property is involved.

Williams v. Raimondo · filed 2025-05-05(e)

The general venue provision, 28 U.S.C. § 1391, applies to the FMLA and constitutional claims. ... Venue is not proper in the District of Columbia under this provision either. ... The Eastern District of Virginia is thus the proper forum for the FMLA and constitutional claims.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits an action against a federal agency in a district where a substantial part of the events occurred, the property at issue is situated, or the plaintiff resides if no real property is involved.

Chavez v. HUD "Portability" Does 1-9 · filed 2025-01-24(e)(1)(B), (C)

That being said, because it appears that the alleged events giving rise to these claims have occurred in Los Angeles, California; the real property at issue, if there is any, is located there; and/or because Plaintiff also resides in that city, which lies within the Central District of California, see 28 U.S.C. § 84(c)(2); the United States District Court for the Central District of California is a proper venue for these claims, under Section 1391(e)(1)(B) and/or (C).
Read the full opinion on CourtListener →

Section 1391(c)(2) treats a federal agency as residing in any judicial district where it is subject to personal jurisdiction for purposes of venue under § 1391(e)(1)(A).

Ironridge Global IV, Ltd. v. Securities & Exchange Commission · filed 2015-11-17(c)(2)

The Court finds that Plaintiffs’ have shown a likelihood of success on the merits that the SEC resides in-this district pursuant to §§ 1391(c) and 1391(e)(1)(A).
Read the full opinion on CourtListener →

Section 1391(e) permits venue against a federal agency in a district where an unincorporated plaintiff does business, even when nonfederal defendants are joined.

Brotherhood of Locomotive Engineers v. Denver & Rio Grande Western Railroad · filed 1968-09-09(e)

Since section 1391(e) is properly applicable in the instant case, the defendant NMB’s objection to venue must also fall. As against the NMB particularly, venue is proper in this district under section 1391(e) by virtue of plaintiff’s residence here; unincorporated associations are to be viewed, for venue purposes, as residents of any district where they are doing business.
Read the full opinion on CourtListener →

Section 1391(e) does not apply to defendants lacking a sufficient connection to the United States government to qualify as federal agencies.

Dennie v. University of Pittsburgh School of Medicine · filed 1984-06-08(e)

Thus, we hold Dr. Wald, the Hospital and the Medical School not to be agencies within the terms of section 1391(e), and this Court may not exercise jurisdiction over them on its authority.
Read the full opinion on CourtListener →

Section 1391(e) governs venue for actions against the federal government when the statute creating the claim has no special venue provision.

Rebar v. Marsh · filed 1992-04-28(e)

Since there is no venue provision in the Age Discrimination in Employment Act itself, we hold that the general venue statute applies and that venue of this case was in the Middle District of Florida where the plaintiff lives.
Read the full opinion on CourtListener →

Section 1391(e) permits venue for claims against federal defendants where either party resides or where a substantial part of the events or omissions giving rise to the claim occurred.

Marin v. Shaw · filed 2009-04-06(e)

The district court properly dismissed without prejudice the claims against the ...federal defendants for improper venue and lack of subject matter jurisdiction. See 28 U.S.C. § 1391(e) (instructing that venue is proper where either the defendant or plaintiff resides, or where a substantial part of the events or omissions giving rise to the claim occurred).
Read the full opinion on CourtListener →

Section 1391(e)(1)(C) permits a civil action against a United States agency that involves no real property to be brought in the judicial district where the plaintiff resides.

Sung Chan v. Eric H. Holder, Jr. · filed 2012-12-11(e)(1)(C)

Finally, based upon the information in the record, we conclude that the United States District Court for the Southern District of New York is the appropriate court to address this matter. See 28 U.S.C. § 1391(e)(1)(C) (civil action, in which defendant is United States agency, may be brought in any judicial district in which plaintiff resides if no real property is involved in action).
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue where a federal agency defendant resides, including the district where it is headquartered.

Houston v. Stuckey · filed 2014-10-21(e)(1)

Additionally, venue IS proper because the USDA is headquartered in Washington, D.C. See 28 U.S.C. S 1391(e) (1) (venue is proper in any district where a defendant resides).
Read the full opinion on CourtListener →

Section 1391(e)(1) does not establish venue for a claim against a federal agency based solely on the location of its headquarters.

Chandler v. Stover · filed 2016-09-30(e)(1)

The plaintiff cannot point to the location of the BOP’s headquarters alone to establish venue in this district.
Read the full opinion on CourtListener →

Section 1391(e) permits a suit challenging federal agency action where a defendant resides, where a substantial part of the relevant events occurred, or where the plaintiff resides if no real property is involved.

State v. U.S. Army Corps of Eng'rs · filed 2018-03-29(e)

In suits challenging federal agency action, venue is proper in any district in which "(A) a defendant in the action resides, (B) a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated, or (C) the plaintiff resides if no real property is involved in the action." ... Hence, this suit could have been brought in either of the proposed transferee districts.
Read the full opinion on CourtListener →

Section 1391(e)(1)(A) does not provide venue for a suit against federal agencies rather than federal officers or employees.

Grant II v. Central Intelligence Agency · filed 2019-12-20(e)(1)(A)

However, this section does not apply here because Defendants are not “officer[s] or employee[s] of the United States or any agency thereof.”
Read the full opinion on CourtListener →

Section 1391(e)(1) does not provide venue in a district where the plaintiff does not reside and neither the defendant nor the challenged conduct is located.

Samhi v. US Consulate General Casablanca · filed 2021-01-04(e)(1)

Plaintiff’s subsequently filed amended complaint failed to address the venue issue, and the Court must therefore determine that venue does not lie in this district where the action involves an Arizona plaintiff, a U.S. consulate abroad, and conduct that did not occur in Washington. See 28 U.S.C. § 1391(e)(1).
Read the full opinion on CourtListener →

Section 1391(e)(1) permits a plaintiff to sue a federal agency in the district where the plaintiff resides, but does not provide venue for an individual-capacity money-damages claim against a federal employee.

Taraldsen v. Federal Bureau Of Prisons · filed 2021-02-26(e)(1)

Because Taraldsen currently resides in Nevada, 28 U.S.C. § 1391(e)(1) allows him to bring a claim in this district against the Federal Bureau of Prisons. But that provision does not apply to Taraldsen’s claim against Baca in her individual capacity for money damages.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue for a federal question claim against a federal agency or official where a substantial part of the events giving rise to the claim occurred.

Aiken v. Federal Bureau of Prisons Director · filed 2021-04-15(e)(1)

Her Eighth Amendment claim against the federal defendants is governed by the general venue statute, which provides that in actions raising a federal question by naming as a defendant a federal agency or United States official in his or her official capacity, venue is proper in any judicial district where (1) “a defendant in the action resides;” (2) “a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated;” or (3) a “plaintiff resides if no real property is involved in the action.” 28 U.S.C. § 1391(e)(1). The conduct primarily at issue in this case occurred in S.D.W.V. and thus both plaintiff’s Eight Amendment and FTCA claims may have been brought in that district.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue for a mandamus or APA claim against a federal agency where the plaintiff resides if no real property is involved, or where a substantial part of the events giving rise to the claim occurred.

Jin v. United States Citizenship and Immigration Services · filed 2022-10-03(e)(1)(B), (C)

Thus, while Plaintiff has alleged no facts showing that this Court is a proper venue for this action, because Plaintiff resides in Queens County, and because the alleged events giving rise to Plaintiff’s claims may have occurred in Nassau County, the United States District Court for the Eastern District of New York is a proper venue for this action. See id. § 1391(e)(1)(B), (C).
Read the full opinion on CourtListener →

Section 1391(e)(1)(C) permits venue for a mandamus or APA action against a federal agency in the district where the plaintiff resides if no real property is involved.

Pierre v. Immigration Service USCIS · filed 2023-02-23(e)(1)(C)

Absent such allegations, the “judicial district in which . . . the plaintiff resides,” 28 U.S.C. § 1391(C)—i.e., the Eastern District of New York—is the proper venue. See § 1391(e)(1)(C).
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue where USCIS has its headquarters for an action seeking to compel a decision on an immigration petition.

Karaoglu v. US Department of Homeland Security · filed 2023-07-19(e)(1)

Maryland is, by virtue of the location of USCIS headquarters, a viable venue for plaintiffs seeking to compel a decision on their petitions.
Read the full opinion on CourtListener →

Section 1391(e)(1) does not establish venue in Maryland for an asylum-delay suit solely because USCIS is headquartered there when the application is processed in Virginia.

Bulut v. US Department of Homeland Security · filed 2023-08-10(e)(1)

As this court has consistently determined, “the fact that USCIS is headquartered here . . . alone is insufficient to establish proper venue in Maryland.” ... The Court therefore will transfer this action to the Eastern District of Virginia.
Read the full opinion on CourtListener →

Section 1391(e)’s plaintiff-residence venue rule does not apply to workplace disability discrimination claims against a federal employer.

Hammack v. Becerra · filed 2024-03-15(e)

Ms. Hammack asserts that under 28 U.S.C. § 1391(e), a civil action against an officer of the United States or agency “may... be brought in any judicial district in which . . . the plaintiff resides if no real property is involved in the action.” However, that venue statute does not apply if the case concerns allegations of workplace disability discrimination and harassment against a federal employer.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue where a federal defendant has its headquarters.

Reyes v. United States Citizenship and Immigration Services · filed 2024-04-25(e)(1)

Maryland is, by virtue of the location of USCIS headquarters, a viable venue for plaintiffs seeking to compel or review a decision on their petitions.
Read the full opinion on CourtListener →

Section 1391(b)(1) makes venue proper in the district where a sole defendant resides.

Parmer v. Entrust Corporation · filed 2024-04-29(b)(1)

Thus, Entrust resides in the District of Minnesota, and, accordingly, that district would have been a proper venue for this matter. 28 U.S.C. § 1391(b)(1).
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue in the district where USCIS headquarters is located for a suit seeking action on an immigration petition.

Romero v. United States Citizenship and Immigration Services · filed 2024-07-16(e)(1)

Maryland is, by virtue of the location of USCIS headquarters, a viable venue for plaintiffs seeking to compel or review a decision on their petitions.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue in an action against federal agencies or officials in the district where the plaintiff resides.

Patel v. Mayorkas · filed 2024-11-15(e)(1)

The Court agrees with Defendants that this case could have been brought in the Middle ... District of Florida because Patel resides there. See ECF 1 at 1 (listing Patel’s address in Jacksonville, Florida); 28 U.S.C. § 1391(e)(1) (providing that, in actions naming federal agencies or officials as defendants, venue is proper, inter alia, in the district where the plaintiff resides).
Read the full opinion on CourtListener →

Section 1391(e)(1)(A) permits venue in the district where a federal agency defendant is headquartered.

Zhang v. Department of Homeland Security · filed 2024-12-10(e)(1)(A)

Here, venue is proper in this district under 28 U.S.C. § 1391(e)(1)(A) because DHS is headquartered in Washington, D.C.
Read the full opinion on CourtListener →

Section 1391(e)(1)(A) does not make a district a federal agency’s residence merely because the agency maintains an office there.

Huddleston v. Garland · filed 2025-07-25(e)(1)(A)

Thus, the location of the USCIS Nebraska Service Center—merely an office maintained in this state by USCIS—does not establish that this District is a proper venue for this action, even if the action could be asserted against the USCIS Nebraska Service Center.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits venue in an action against federal defendants where a defendant resides, substantial events occurred or relevant property is located, or the plaintiff resides if no real property is involved.

Moore · filed 2026-01-12(e)(1)

Because Plaintiff does not allege that any defendant resides in this District, venue is not proper here under Section 1391(e)(1)(A). Venue is not proper here under Section 1391(e)(1)(B) because the events giving rise to Plaintiffs claims did not occur here, nor do his claims involve property located in this District. Finally, venue is not proper in this District under Section 1391(e)(1)(C) because Plaintiff does not reside in this District.
Read the full opinion on CourtListener →

Section 1391(e)(1) permits an action against the United States, its agencies, or its officers or employees acting officially in a district where a defendant resides, a substantial part of the events occurred, or the plaintiff resides if no real property is involved.

Lattimore · filed 2026-04-03(e)(1)

28 U.S.C. § 1391(e)(1)—which applies in actions like this one where a defendant is the United States or one of its agencies or officers or employees “acting in his official capacity or under color of legal authority”—states, in relevant part, that a civil action may be brought in “any judicial district in which” (1) “a defendant in the action resides,” (2) “a substantial part of the events or omissions giving rise to the claim occurred,” or (3) “the plaintiff resides if no real property is involved in the action.” Plaintiff’s amended complaint does not indicate that the District of Arizona is the correct venue under any of these statutory options.
Read the full opinion on CourtListener →

Venue generally

Section 1391(e) creates no new liabilities or causes of action against the United States.

Tejidos Konfort, Inc. v. McAuliffe · filed 1968-10-22(e)

The 1962 enactment of 28 U.S.C. § 1361 and 28 U.S.C. § 1391(e) creates no new¡ liabilities or new causes of action against the United States.
Read the full opinion on CourtListener →

Law changed since Pub. L. 101-650 (Dec. 1, 1990) removed a plaintiff’s residence as an independent ground for general diversity venue.

Section 1391(a) permits a diversity action in the district where all plaintiffs or all defendants reside, while subsection (c) treats a corporation as residing where it is incorporated, licensed to do business, or doing business.

Weissfeld v. Herman Miller, Inc. · filed 1968-12-20(a)

According to 28 U.S.C. § 1391(a), a civil action based on diversity jurisdiction may be brought only in the judicial district where all of the plaintiffs or all of the defendants reside. For purposes of federal venue, a corporation is regarded as residing in any judicial district in which it is incorporated, licensed to do business or is doing business. 28 U.S.C. § 1391(c).
Read the full opinion on CourtListener →

Section 1391 permits venue where the plaintiff's claim arose.

Novel v. Garrison · filed 1969-01-02

Since I hold that plaintiff has adequately alleged that defendant Garrison has committed a tortious act within Illinois, his motion to dismiss for improper venue is without merit, as plaintiff’s claim arose here. (28 U.S.C. § 1391).
Read the full opinion on CourtListener →

Law changed since Same change as noted above.

Section 1391(a) permits a diversity plaintiff to sue where the plaintiff resides, where the defendant resides, or where the claim arose, while § 1391(c) does not override those choices.

Swift Industries, Inc. v. Botany Industries, Inc. · filed 1969-04-02(a), (c)

28 U.S.C. § 1391 is a general venue statute. Fourco Glass Co. v. Transmirra Corp., 353 U.S. 222, 77 S.Ct. 787, 1 L.Ed.2d 786 [1957]. There is no special venue statute covering this type of action which takes precedence over it. Under the clear and unambiguous language of § 1391(a) the plaintiff, in an action based solely on diversity, may choose to bring his action either in the district where plaintiff resides or where defendant resides or in which the claim arose. ... § 1391(c) is also a general venue statute applicable to actions against corporations. It does not prevail over the specific provisions of § 1391(a) of the same statute. ... We conclude that venue is proper in this District.
Read the full opinion on CourtListener →

Law changed since Same change as noted above.

Section 1391(a) permits venue in a district where the plaintiff or defendants reside or where the claims arose.

Nowell v. Dick · filed 1969-10-28(a)

Venue, in this diversity case, was proper in either the district where the plaintiff resided, where the defendants resided, or where the claims arose. 28 U.S.C. § 1391(a). Since the defendants were residents of Texas, the venue of the Texas federal court was proper.
Read the full opinion on CourtListener →

Law changed since Same change as noted above.

Section 1391(a) makes venue unavailable in a diversity action when both the plaintiff and defendant are nonresidents of the district.

Iris Calder Nowell v. Nowell · filed 1969-11-17(a)

In the present diversity situation, where both the plaintiff and the defendant are nonresidents of the district, the venue requirements are insurmountable. 28 U.S.C. § 1391(a).
Read the full opinion on CourtListener →

Section 1391(e) permits venue against federal defendants even when other defendants are not officers or employees of the United States.

Tenants & Owners in Opposition to Redevelopment v. United States Department of Housing & Urban Development · filed 1970-04-30(e)

The federal defendants further argue that venue as to them does not lie in this Court under 28 U.S.C. § 1391(e) because not all defendants are officers or employees of the United States. This claim must fall under the decisions in Macias v. Finch, 324 F.Supp. 1252 (N.D.Cal.1970) and in Powelton Civic Home Owners Ass’n v. Department of Housing and Urban Development, 284 F.Supp. 809 (E.D.Pa.1968). The reasoning in those cases makes it clear that this Court has personal jurisdiction over the defendant Romney and that venue here is proper.
Read the full opinion on CourtListener →

Section 1391(e) establishes venue for suits against federal officers but does not broaden the availability of habeas corpus relief.

Carney v. Secretary of Defense · filed 1971-04-14(e)

Insofar as jurisdiction is asserted against the Secretary of Defense, the Secretary of the Navy and the Chief of Naval Operations, under 28 U.S.C. § 1391(e), I must agree. That provision relates only to proper venue and was not intended by Congress to broaden the availability of habeas corpus relief, and I read it not to have done so.
Read the full opinion on CourtListener →

Section 1391 establishes venue rules for the convenience of the parties.

Alvarado v. Saxby · filed 1972-02-25

Section 1391 of Title 28 U.S.C. is a venue statute for the convenience of parties.
Read the full opinion on CourtListener →

Section 1391(e) permits this type of action in a district where a defendant resides or the cause of action arose.

Henry E. Outlaw, Jr. v. L. M. Connett, Warden, Federal Correctional Institution · filed 1972-02-28(e)

However under the provisions of the venue statute, 28 U.S. C. § 1391(e)* this action can not be maintained in the Northern District of Texas where neither of the parties resides nor the cause of action arose.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where all defendants reside or where the claim arose.

National Ass'n for Community Development v. Hodgson · filed 1973-03-30(b)

This provision locates venue in the judicial district (1) “where all the defendants reside” or (2) “in which the claim arose”. ... In short, although only one is needed, both of the Section 1391(b) venue bases are satisfied in that the defendant resides in the District of Columbia and the claim arose in the District of Columbia. Therefore, defendant I.C.E.S.A.’s claim of improper venue has no merit.
Read the full opinion on CourtListener →

Section 1391 permits venue based on defendants’ residence or where a substantial part of the events giving rise to the claim occurred; a defendant’s residence for this purpose can depend on personal jurisdiction.

Mid-Continent Cas. Co. v. Greater Midwest Builders, LTD · filed 2018-02-12(b)(1), (b)(2), (c)(2)

The Court has rejected that jurisdictional challenge; thus, venue is proper under this provision. Moreover, as MCC points out, venue would also be proper under Section 1391(b)(2) because a substantial part of the events giving rise to the claim occurred in Kansas.
Read the full opinion on CourtListener →

Section 1391(b)(1) and (2) provide venue based on defendants’ residence or a substantial part of the events or omissions giving rise to the claim.

Lina Lam v. Liberty Mutual Group, Inc. · filed 2018-03-23(b)(1), (b)(2)

The district court properly dismissed Lam’s claims against Martin and Multiple Concrete, Inc. because Lam failed to establish that these defendants reside in the Central District of California or that “a substantial part of the events or omissions giving rise to [her] claim[s]” occurred there. 28 U.S.C. § 1391(b)(1), (2) (describing where a civil action may be brought).
Read the full opinion on CourtListener →

Section 1391(b)(2) does not establish venue based on vague references to wages and bank accounts in a district when the claim concerns proceedings elsewhere.

Mosier v. Farren · filed 2018-04-25(b)(2)

Thus, the only possible route to venue lies in § 1391(b)(2), which establishes that venue is proper in a judicial district in which a substantial part of the events relevant to the action occurred, or where a substantial part of property that is the subject of the action is situated. ... So the district court was correct to reject Mosier’s vague references to garnished wages and emptied bank accounts. And venue was improper in the District of Colorado.
Read the full opinion on CourtListener →

Section 1391(b) identifies the districts where a civil action may be brought.

Stanley v. Marriott International, Inc. · filed 2018-06-14(b)

Mr. Stanley could have sued Columbia Sussex in Florida, Kentucky or Illinois under § 1391(b).
Read the full opinion on CourtListener →

Section 1391 governs venue for civil rights claims when their governing act contains no specific venue provision.

Boswell v. MTC Unit · filed 2024-01-22

The Civil Rights Act, 42 U.S.C. §1981, et seq., under which this case is brought, does not contain a specific venue provision. Accordingly, venue in civil rights cases is controlled by 28 U.S.C. § 1391.
Read the full opinion on CourtListener →

Section 1391(b) permits a civil action to be brought in a district where a substantial part of the events giving rise to the claim occurred.

(PC) Robertson v. Welsh · filed 2024-01-24(b)

In this case, the defendants are located, and the claim arose in Napa County, which is in the Northern District of California.
Read the full opinion on CourtListener →

Section 1391(b) does not establish venue in a district where the defendants reside elsewhere, no substantial part of the events occurred, and none of the property at issue is located.

Jaylee v. Sutton · filed 2024-01-26(b)

Therefore, venue is not proper in the Eastern District of Washington under 28 U.S.C. § 1391(b).
Read the full opinion on CourtListener →

Section 1391(b) permits venue based on defendants’ residence, a substantial part of the events giving rise to the claim, or a substantial part of the property at issue.

(PS) Stiles v. Kahn · filed 2024-01-26(b)

On the other hand, the complaint’s allegations do not establish that a substantial part of the events or omissions giving rise to the claim occurred in this district. Venue does not lie in this district. See 28 U.S.C. § 1391(b).
Read the full opinion on CourtListener →

Section 1391(b) does not provide venue in a district where no defendant appears to reside or be subject to personal jurisdiction and none of the events giving rise to the claims occurred.

Hoffman v. Rule · filed 2024-01-26(b)

For any Bivens claims, venue is improper in the District of Idaho because all defendants likely would be Indiana residents, the events giving rise to Petitioner’s claims all occurred in Indiana, and it does not appear that any defendant is subject to the personal jurisdiction of this Court. See 28 U.S.C. § 1391(b).
Read the full opinion on CourtListener →

Section 1391(b) does not permit venue in a district where no defendant resides and none of the events giving rise to the claim occurred.

Benton v. Home Max Realty, Inc. · filed 2024-01-30(b)

Based on these rules and the foregoing discussion of Defendants’ residencies and personal jurisdiction, it is apparent that venue is improper in the Eastern District of Virginia. None of the Defendants reside in Virginia, let alone the Eastern District, and the “events or omissions giving rise to [Plaintiff’s] claim” all occurred in Florida, not Virginia.
Read the full opinion on CourtListener →

Section 1391(b) places venue in a district where a defendant resides or where a substantial part of the events giving rise to the claim occurred.

Bajra 407332 v. Tanner · filed 2024-01-30(b)

Under the revised venue statute, venue in federal-question cases lies in the district in which any defendant resides or in which a substantial part of the events or omissions giving rise to the claim occurred. 28 U.S.C. § 1391(b). ... In these circumstances, venue is proper only in the Eastern District.
Read the full opinion on CourtListener →

Section 1391(b) permits venue in a district where the remaining defendants reside and the events giving rise to the action occurred.

Coles v. Dalton · filed 2024-01-31(b)

Pursuant to 28 U.S.C. § 1391(b), venue is proper for the remaining action in the Western District of Virginia and not in the Eastern District of Virginia.
Read the full opinion on CourtListener →

Section 1391 supported transferring the action to the Northern District of Alabama after the court rejected objections to that venue.

Cargill v. United States of America (INMATE 2) · filed 2024-02-01

However, the Plaintiff’s objections do not undermine or change the Recommendation’s ... findings and conclusion that the Northern District of Alabama is the proper venue in this case.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where any defendant resides if all defendants reside in that state, or where a substantial part of the events or omissions giving rise to the claim occurred.

Rusk v. Kartchner · filed 2024-02-05(b)

A civil case may be filed in “(1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located; [or] (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.” 28 U.S.C. § 1391(b). ... Mr. Rusk’s motions to add these Montana-based defendants and causes of action are therefore denied.
Read the full opinion on CourtListener →

Section 1391(b) does not permit venue in a district where the defendant does not reside and none of the alleged events occurred when another district is available.

Lettieri v. Powell · filed 2024-02-05(b)

He does not allege that the events giving rise to the complaint occurred in the Western District of New York. Venue therefore is not proper in this district.
Read the full opinion on CourtListener →

Section 1391 did not permit venue in South Carolina where no defendant resided and no alleged event or omission giving rise to the claim occurred.

Proctor v. Vican · filed 2024-02-05

none of the named Defendants reside in South Carolina, and Plaintiff has not alleged that any of the events or omissions that gave rise to this claim occurred in this district.2 Therefore, venue under ... 28 U.S.C. § 1391 is inappropriate in the District of South Carolina. ... Therefore, the Court adopts the Report (DE 6) and incorporates it here by reference.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.

Newton v. Akers · filed 2024-02-06(b)

Given these well-pleaded facts, we lack venue over these claims and parties.
Read the full opinion on CourtListener →

Section 1391(b) does not permit venue in a district unconnected to the defendants or the events giving rise to the claim when another district is available.

Graves v. Name Unknown 1 · filed 2024-02-08(b)

Graves’s complaint seems to allege that the two corrections officers involved in the incident are employed by, and the complained-of civil rights violations allegedly occurred at, TDCJ’s Hughes Unit, which is located in Gatesville, Coryell County, Texas. ... As a result, Graves’s complaint was not properly filed in this district.
Read the full opinion on CourtListener →

Section 1391(b) makes venue improper where no defendant resides, no substantial part of the events occurred, and the action can be brought in another district.

Johnson (PS) v. Brady · filed 2024-02-08(b)

Subsection (1) is not met. The parties appear to reside in Colorado, and it is not clear this Court has personal jurisdiction over any Defendant. ... Accepting the allegations as true, none of the alleged wrongdoing occurred in New Mexico. The claims stem from events in a Colorado prison and/or a Colorado criminal proceeding. Subsection (3) does not apply. It appears Plaintiff can file an action in the Colorado Federal Court, and he wishes to proceed in that venue.
Read the full opinion on CourtListener →

Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.

Demos v. Trump · filed 2024-02-12(b)

Section 1391(b) of the United States Code, title 28, provides that venue for a civil action is proper in either the judicial district in which any defendant resides or in the judicial district in which a substantial part of the events or omissions giving rise to the claim occurred. ... Venue therefore properly lies in either the Southern District of Florida or the District of Columbia.
Read the full opinion on CourtListener →

Notes 2101–2250 of 8,639, oldest cases first.

Which of these rulings fit your facts?

Describe your situation under 28 U.S.C. § 1391. Ezel checks it against the cases on this page and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace