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No reviewed case has held this section invalid, preempted, superseded or repealed.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.

Venue generally

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

Rice v. Mosley · filed 2024-02-20(b)

Therefore, under § 1391, the Plaintiff’s action may be heard in a venue ... substantially arose, which here is the Eastern District of Kentucky.
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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.

Flakes 407798 v. Reed · filed 2024-02-20(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 of Michigan.
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Section 1391(b) makes venue improper in a district where no defendant resides and none of the events giving rise to the claim occurred when the action can be brought in another district.

Philips v. Pitt County Memorial Hospital · filed 2024-02-20(b)

Accordingly, pursuant to § 1391(b), venue is not proper in the Western District of North Carolina.
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Section 1391(b) permits venue where a defendant resides or a substantial part of the events giving rise to the claim occurred; a public official resides where the official serves for a suit challenging official acts.

Johnson 251307 v. Walk · filed 2024-02-26(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). The events underlying the complaint occurred in Macomb County. Defendants are public officials serving in Macomb County, and they “reside” in that county for purposes of venue over a suit challenging official acts. See Butterworth v. Hill, 114 U.S. 128, 132 (1885); O’Neill v. Battisti, 472 F.2d 789, 791 (6th Cir. 1972). Macomb County is within the geographical boundaries of the Eastern District of Michigan. 28 U.S.C. § 102(a). In these circumstances, venue is proper only in the Eastern District.
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Section 1391(b) permits venue in a district where a defendant resides if all defendants reside in the same state, or where a substantial part of the events giving rise to the claim occurred.

Sabino v. City of New York · filed 2024-02-27(b)

Civil actions are properly 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). ... Here, venue is not proper in the Eastern District of New York. Sabino seeks to challenge an arrest made in New York County and sues defendants located in New York County.
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Section 1391(b)(1) and (2) permits venue based on defendant residence or a substantial part of the events or omissions giving rise to the claims.

Skrbic v. City of West Palm Beach · filed 2024-02-28(b)(1), (2)

The district court properly dismissed Skrbic’s action for improper venue because Skrbic failed to establish that defendant resides in the Western District of Washington or that a substantial part of the events or omissions giving rise to his claims occurred there.
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Section 1391(b) places venue in a district where a defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred.

Cozart v. Tulsa Public Defenders Office · filed 2025-02-21(b)

Pursuant to 28 U.S.C. § 1391(b), the proper venue for Plaintiff’s action is in the “judicial district in which any defendant resides” or the “judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.” ... Here, it is clear from ... the face of the Complaint that venue is improper because Plaintiff has not identified any defendant as residing within the Western District of Oklahoma and no events are alleged to have occurred in the Western District of Oklahoma.
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Section 1391(b) permits venue where the defendants reside or a substantial part of the events occurred; its fallback applies only if no district otherwise qualifies.

Clark v. 32 Sports Inc · filed 2025-02-24(b)

Under the alleged facts of this case, this statute does not provide venue in the District of the Massachusetts. Subsection (1) is inapplicable because the defendants are not residents of Massachusetts. Subsection (2) does not support venue in this Court because the events giving rise to Clark’s claims did not occur in Massachusetts.
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Section 1391(b) does not permit venue in Kentucky for claims against a New York resident when no Kentucky connection is alleged.

Johnson v. Kirwan · filed 2025-02-25(b)

This Court is obviously not a proper venue to assert claims against a New York resident. See 28 U.S.C. § 1391(b).
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Section 1391 does not establish venue in a district where none of the events or omissions giving rise to the claims occurred and no other basis for venue exists.

Chen v. Blinken · filed 2025-02-25

The court nevertheless dismisses Plaintiff Yan’s claims without prejudice because venue is not properly laid in this District. See 28 U.S.C. § 1391. Plaintiff Yan resides in California, none of the events or omissions giving rise to Plaintiff Yan’s claims occurred in this District, and Plaintiff Yan is not subject to this court’s per- sonal jurisdiction with respect to his claims. (Compl. 4 7.) See 28 U.S.C. § 1391.
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Section 1391(b)(1) and (2) permit venue based on a defendant’s residence or a substantial connection to the events or property at issue.

Bourne v. The Administrative Office of the United States Courts · filed 2025-02-25(b)(1), (2)

It is therefore clear from the face of the complaint that venue is not proper in this Court under Section 1391(b)(1), (2).
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Section 1391(b)(1) and (2) do not establish venue in a district where no defendant is alleged to reside and no substantial part of the events giving rise to the claims occurred.

Ruff v. Carter · filed 2025-02-26(b)(1), (b)(2)

Thus, from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).
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Section 1391(b) does not establish venue in a district where no defendant resides, no substantial part of the events giving rise to the claims occurred, and no defendant appears subject to personal jurisdiction.

Ardis v. Dickey · filed 2025-03-03(b)

Furthermore, Judge Jones properly found that the operative Amended Complaint fails to allege proper venue in accordance with 28 U.S.C. § 1391(b); none of the Defendants reside in this district, a substantial part of the events giving rise to Plaintiffs claims occurred in Florida and/or South Carolina, not in this district, and given the allegations, it is unlikely any Defendant would be subject to personal jurisdiction in this district.
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Section 1391(b) permits venue where a defendant resides or substantial events underlying the claim occurred, with a personal-jurisdiction fallback when no other district is available.

Johnson v. Gentzler · filed 2025-03-03(b)

Subsection (1) is not met. The parties all reside in Colorado, and it is not clear this Court has personal jurisdiction over any Defendant. See 28 U.S.C. § 1391(c)(2) (for venue purposes, an entity resides in any district “in any judicial district in which such defendant is subject to the court’s personal jurisdiction with respect to the civil action in question”). As to subsection (2), courts must examine “the nature of the plaintiff’s claims and the acts or omissions underlying those claims” and determine whether “substantial events material to those claims occurred” in this district. Emps. Mut. Cas. Co. v. Bartile Roofs, Inc., 618 F.3d 1153, 1166 (10th Cir. 2010). 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 that Plaintiff can file an action in the Colorado Federal Court.
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Law changed since The opinion uses the pre-2012 federal-question venue formulation. For actions commenced on or after January 6, 2012, § 1391(b)(2) instead asks whether a substantial part of the events or omissions giving rise to the claim occurred in the district.

Section 1391 permits venue in a judicial district where the defendants reside or where the claim arose when jurisdiction is not founded solely on diversity of citizenship.

Hawkins v. Burks · filed 2025-03-03

When, as in this case, jurisdiction is not founded solely on diversity of citizenship, 28 U.S.C. § 1391 provides that venue is proper only in the judicial district where the defendants reside or in which the claim arose.
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Law changed since Same change as noted above.

Section 1391(b) permits venue where defendants reside or where the claim arose when jurisdiction is not founded solely on diversity of citizenship.

Fields v. Gilley · filed 2025-03-04(b)

When jurisdiction is not founded solely on diversity of citizenship, 28 U.S.C. § 1391(b) provides that venue is proper in the judicial district where the defendants reside or in which the claim arose. Venue is not proper in the Eastern District of Texas, because Plaintiff alleges that the claims arose in Lee County, Virginia.
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Section 1391(b) permits venue where the defendants reside or where a substantial part of the events giving rise to the claims occurred.

Both v. MAV Group, LLC · filed 2025-03-10(b)

Venue of claims under the general venue statute is proper in the District of Nevada, under Section 1391(b)(1), (2), based both on where Defendants reside and where the claims arose.
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Section 1391(b) does not permit venue in a district where no defendant resides, no substantial part of the relevant events occurred, and another district is available.

Henderson v. United States · filed 2025-03-11(b)

Subsection (1) is not met. ... As to subsection (2), the facts demonstrate the “substantial events material to th[e individual] claims” did not occur in this district. ... Subsection (3) does not apply because Henderson can file an action in Georgia, where he is incarcerated. Venue is therefore improper with respect to the individual claims that impact Henderson.
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Section 1391(b) does not permit venue in a district where the defendants do not reside and no substantial part of the claims arose when another district is available.

Xelup v. United States Department of Commerce · filed 2025-03-12(b)

Xelup has not alleged that any Virgin Islands defendant resides in the District of Columbia; rather, they appear to reside in the Virgin Islands, where Xelup also alleges that he maintains his “official MAN [] office and staff.” Compl. at 2. Nor has Xelup alleged that a “substantial part of the events . . . giving rise to” his claims against the Virgin Islands defendants occurred in this district, and again, they appear to have occurred in the Virgin Islands.
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Section 1391(b)(1) and (2) do not establish venue in a district where no defendant is shown to reside and none of the alleged events occurred.

Ruff v. Carter · filed 2025-03-12(b)(1), (2)

Thus, from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).
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Section 1391(b) makes venue improper in a district where the defendant does not reside and no substantial part of the events giving rise to the claim occurred.

Sreedhar v. Farrell · filed 2025-03-14(b)(1), (2)

Because Defendant is employed in the federal court in Boston, Massachusetts, and the alleged events occurred there, from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).
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Section 1391(b) permits venue in a district where a substantial part of the events giving rise to the claim occurred.

Vertical Bridge Development, LLC v. The Town of Westlake, Texas · filed 2025-03-17(b)

All municipal actions challenged here occurred in Tarrant County. And both Defendants are located at least partially within Tarrant County. Accordingly, the Court finds that this case could have been properly filed in the Northern District under 28 U.S.C. § 1391.
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Section 1391(b) makes venue improper where no defendant resides and no substantial part of the events giving rise to the claim occurred, when another district is available.

Cotton v. Burrell · filed 2025-03-19(b)

There is no suggestion in the pleading that either of the Defendants resides in Ohio, and the events described in the Complaint took place entirely in Washington D.C. The only proper venue for this case is the District of Columbia.
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Section 1391(b) makes venue improper in a district where no defendant resides and no events giving rise to the claims occurred, when the action could have been brought in another district.

Cleveland v. Chaves · filed 2025-03-26(b)(1)-(3)

Because no defendant resides in this District; no part of the events giving rise to Plaintiff’s claims occurred in this District; and Plaintiff could have brought his claims in the District of Nevada, the Court finds venue is improper in the Eastern District of California. See 28 U.S.C. § 1391(b)(1)-(3).
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Section 1391(b) does not make venue proper in a district where no defendant resides and no substantial part of the events giving rise to the claim occurred, when another district is available.

Greene v. Rite Aid - Culver City · filed 2025-03-27(b)

Lastly, Plaintiff has failed to show that venue is proper in the Eastern District of Missouri. The general venue provisions of 28 U.S.C. § 1391 provide the basis for determining the proper venue for Plaintiff’s claims. Section 1391(b) provides: ... Here, Plaintiff does not claim that any of the parties reside in the Eastern District of Missouri, or that any part of the events or omissions giving rise to his claims occurred here.
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Section 1391(b) does not allow venue in a district where no defendant resides and no events or omissions giving rise to the claim occurred when another proper district is available.

Greene v. Access Services Inc. · filed 2025-03-28(b)

Here, plaintiff does not claim that any of the parties reside in the Eastern District of Missouri, or that any part of the events or omissions giving rise to his claims occurred here. Thus, venue clearly is not proper in this Court under § 1391(b).
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Section 1391(b) permits venue where a 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.

Greene v. 430 South Los Angeles Street, LLC · filed 2025-03-31(b)

Lastly, plaintiff has failed to show that venue is proper in the Eastern District of Missouri. ... Here, plaintiff does not claim that any of the parties reside in the Eastern District of Missouri, or that any part of the events or omissions giving rise to his claims occurred here.
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Section 1391(b) permits venue in the district where the events occurred and the remaining defendants appear to be located.

OSBORNE v. BEASLEY · filed 2025-03-31(b)

As noted above, Plaintiff’s claims arise from his treatment in Tattnall County, which is located in the Southern District of Georgia, and the Defendants who are employed by the prison also appear to be located there. Thus, after dismissing Defendant Beasley and the Macon State Prison, the Court can no longer discern a basis for venue in this Court, and a proper venue for this case would be in the Southern District. See 28 U.S.C. § 1391(b).
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Section 1391(b) permits venue based on a defendant’s residence, the location of substantial events or property, or, if no other district is available, personal jurisdiction over a defendant.

Greene v. LA Care Health Plan · filed 2025-03-31(b)

Plaintiff makes no allegation of an act or omission occurring within the jurisdictional boundaries of this Court, nor does plaintiff allege that he or the defendant resides within this district. None of the requirements of § 1391 are present in this case. Accordingly, venue in the Eastern District of Missouri is not proper.
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Section 1391(b) permits venue where all defendants reside in the same state and at least one resides in the district, or where a substantial part of the relevant events or property is in the district.

Gilberti v. Vance · filed 2025-04-02(b)

Venue is not proper in the District of New Mexico, because: (i) the vast majority of Defendants do not reside in New Mexico; (ii) there are no allegations that the acts and omissions giving rise to Gilberti’s claims occurred in New Mexico; and (iii) the subject property is situated in Florida.
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Section 1391 can make venue proper in a district regardless of the parties’ forum selection agreements.

Guimares v. Metal Transportation LLC · filed 2025-07-10(b)(3), (c)(2)

Irrespective of these agreements, venue is appropriate in this district pursuant to the statute. See 28 U.S.C. § 1391(b)(3), (c)(2).
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Section 1391(b)(1) and (2) permit venue where a defendant resides if all defendants reside in that state, or where a substantial part of the events giving rise to the claim occurred.

Endeley v. Rajkumar · filed 2025-07-15(b)(1), (b)(2)

Because Defendant does not reside in this District and the events giving rise to Plaintiff’s claims did not occur in this District,1 from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).
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Administrator’s residence for venue

Section 1391(a) treats an administrator’s personal residence as the administrator’s residence for venue purposes.

Smith v. Harris · filed 1970-01-14(a)

The administrator’s personal residence is his place of residence for purposes of venue under 28 U.S.C. § 1391(a). Nunn v. Feltinton, 294 F.2d 450, 453 (5th Cir. 1961).
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Section 1391(d)'s venue rule for aliens also permits suit against a U.S. citizen with no U.S. residence.

Zin-Plas Corp. v. Plumbing Quality AGF. Co. Ltd. · filed 1985-08-15(d)

The rational of Brunette Machine Works, Ltd. should apply with equal force to a United States citizen without a United States residence, such as Freed. Indeed, the failure to apply the venue provisions of section 1391(d) to Freed would preclude plaintiff from bringing an action in any federal court against him.
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Section 1391(b) and (c) support venue where the defendant is deemed to reside because of sufficient contacts with the district.

Patagon Management LLC v. Wu · filed 2023-05-08(b), (c)

Venue is proper pursuant to 28 U.S.C. § 1391(b) and (c) because Defendant is deemed to reside in any judicial district in which he is subject to the Court’s personal jurisdiction, and because Defendant provides and markets his services within the United States, and in this district, thus establishing sufficient contacts to give the Court personal jurisdiction over Defendant.
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Section 1391(b) does not establish venue in a district based on a defendant’s headquarters when those headquarters are in another district.

Nova Nordeplast Indstria E Comrcio DE Plasticos LTDA v. John Does Corporations 1-5 · filed 2024-03-29(b)

Plaintiffs’ reliance on the location of Chase’s headquarters—especially when incorrect—does not assist the Court in determining whether venue is appropriate in this District.
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Venue at place of incarceration

Section 1391(e) permits venue in the district where a petitioner was incarcerated when the petition was filed.

Avrutine v. United States · filed 1970-04-14(e)

The venue in this ease is proper since petitioner was incarcerated at the Federal Correctional Institution, Danbury, Connecticut, in this district, at the time his petition was filed. 28 U.S.C. § 1391(e).
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For venue under Section 1391(e)(4), a prisoner resides where confined.

In Re Lawrence C. Pope · filed 1978-05-16(e)(4)

In keeping with its policy of convenience, we have held that for purposes of the general venue statute a prisoner has his residence at his place of confinement. ... Since venue is proper in the Southern District of Texas under Section 1391(e)(4), petitioner’s argument that the District Court lacked power to transfer is without merit.
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For venue under § 1391(b) in a non-diversity federal case, an incarcerated defendant resides in the district of confinement.

Kohut v. Henkel · filed 1983-11-04(b)

This Court is convinced that in the above-captioned case, the Defendant, Richard Henkel, is a resident of the district of his incarceration for purposes of venue in this non-diversity federal case.
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Section 1391(a) permits a diversity action to be brought in the district of the defendant’s principal place of business.

Pinto v. Internationale Set, Inc. · filed 1986-08-20(a)

This action could have been brought in the Central District of California, defendant's principal place of business. 28 U.S.C. § 1391(a).
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Under § 1391(e), incarceration does not change a prisoner's residence for venue purposes.

Abreu v. United States · filed 1992-06-04(e)

First, the government argues that the Court should dismiss the motions for inappropriate venue under 28 U.S.C. § 1391(e). This is patently incorrect. Under the venue statute, a prisoner does not change residence to prison simply because she is incarcerated there.
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Congressional officers and employees

Section 1391(e) extends its venue and service provisions to executive branch officers and employees, but not members or employees of Congress.

Liberation News Service v. Eastland · filed 1970-05-07(e)

This history demonstrates to us that, in enacting §§ 1361 and 1391(e), Congress was thinking solely in terms of the executive branch, to which alone § 1391(e) has thus far been judicially applied. ... However, we prefer to rest our decision on the broader ground that although Mr. Sourwine is undoubtedly an employee of the United States for some purposes, see 5 U.S.C. § 2105, Congressional employees are no more within the intendment of 28 U.S.C. § 1391(e) than the members themselves.
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Habeas corpus actions

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

Aldana v. Warden · filed 2020-08-06(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.
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Section 1391(e) permits venue for an immigration habeas petition in a district connected to the events, witnesses, and parties, even when the petitioner is detained elsewhere.

Farez-Espinoza v. Chertoff · filed 2009-01-28(e)

The federal venue statute, 28 U.S.C. § 1391(e) states: ... In this case, traditional principles of venue favor a finding that venue is proper in this district.
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Section 1391(e) provides nationwide service of process on federal officers but does not extend habeas corpus jurisdiction to persons outside the district court’s territorial limits.

Dunne v. Henman · filed 1989-05-18(e)

While 28 U.S.C. § 1391(e) provides for nationwide service of process on officers of the United States, that statute does not extend habeas corpus jurisdiction to persons outside the territorial limits of the district court.
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Section 1391(e) generally permits nationwide service on federal officers, but it does not provide personal jurisdiction in habeas cases.

Chatman-Bey v. Richard Thornburgh, Attorney General of the United States · filed 1988-12-23(e)

Although 28 U.S.C. Sec. 1391(e) generally provides for nationwide service on officers of the United States, this basis of personal jurisdiction is unavailable in habeas.
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Section 1391(e) treats habeas corpus proceedings as civil actions and permits its venue and service provisions to support personal jurisdiction over federal officials.

United States Ex Rel. Armstrong v. Wheeler · filed 1970-12-02(e)

Since habeas corpus is generally termed a “civil” action and since it was the apparent intent of Congress to “facilitate review by the Federal courts of administrative actions” (precisely the situation presented here), the phrase “civil actions” in § 1391(e) should be read to include habeas corpus actions.
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Section 1391(e) does not govern venue in habeas corpus proceedings because a habeas petition is not a “civil action” within its meaning.

Roman v. Ashcroft · filed 2001-09-06(e)

Nevertheless, the Court finds that § 1391(e) does not apply, because habeas corpus is not a “civil action” within the meaning of the statute.
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Section 1391(e) permits venue in the district where a detained petitioner is held when the official-capacity respondent is the superintendent of the detention facility.

Castaneda v. Souza · filed 2013-07-03(e)

Venue is proper in the District of Massachusetts under 28 U.S.C. section 1391(e) because the petitioner is being held within the district at the Bristol County House of Corrections where Souza, being sued in his official capacity, is the superintendent.
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Section 1391(b) places venue for a petition challenging a conviction in the district where the conviction occurred.

(HC) Sandoval v. On Habeas Corpus · filed 2020-09-01(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.
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Section 1391(b) places venue for a petition challenging a conviction in the district where the conviction occurred.

(HC) Solano v. Sherman · filed 2020-10-22(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.
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Section 1391(b) requires a petition challenging a conviction to be filed in the district where the conviction occurred.

(HC) Valenzuela v. Cates · filed 2021-10-06(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.
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Section 1391(b) places venue for a petition challenging a conviction in the district containing the county of conviction.

(HC) Zaragoza v. On Habeas Corpus · filed 2021-12-20(b)

In this case, the petitioner is challenging a conviction from Orange 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.
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Section 1391(b) places venue for a petition challenging a conviction and sentence in the district where they were issued.

(HC) Noble v. Trate · filed 2022-10-24(b)

Therefore, the petition should have been filed in the United States District Court for the Southern District of Indiana.
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Section 1391(b) places venue for a petition challenging a conviction and sentence in the district that issued them.

NOBLE v. TRATE · filed 2022-10-24(b)

In this case, the petitioner is challenging a conviction and sentence issued from the United States District Court for the Southern District of Indiana. Therefore, the petition should have been filed in the United States District Court for the Southern District of Indiana.
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Section 1391(b) places a petition challenging a conviction in the district where the conviction occurred.

(HC) Kruppe v. Warden · filed 2022-11-21(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 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.
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Section 1391’s general venue rules do not apply to habeas proceedings.

Bondi · filed 2026-02-04

But courts have held that 28 U.S.C. § 1391 does not apply in habeas proceedings.
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Section 1391(e) allows nationwide service of process on federal officers but does not extend a district court’s territorial habeas jurisdiction.

Coalition of Clergy v. Bush · filed 2002-02-21(e)

Moreover, the Ninth Circuit has expressly held that 28 U.S.C. § 1391(e), which provides for nationwide service of process on officers of the United States, does not extend habeas corpus jurisdiction to persons outside the territorial limits of the district court. ... It is clear, then, that because there is no showing or allegation that any named respondent is within the territorial jurisdiction of the Central District of California, this court lacks jurisdiction to issue the writ requested by petitioners.
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Venue for corporations and alien defendants

Section 1391(c)(3) permits venue for a foreign defendant in a district where the court has personal jurisdiction over that defendant.

LogoPaint A/S v. 3D Sport Signs SI · filed 2016-02-18(c)(3)

For the remaining foreign Defendants, venue is proper in any district court assuming they are subject to personal jurisdiction in that forum. 28 U.S.C. § 1391(c)(3). ... Because Florida’s long-arm statute confers personal jurisdiction over all foreign Defendants and the exercise of that jurisdiction comports with due process requirements, this case could have been brought in the Southern District of Florida.
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Law changed since Pub. L. 100-702 (effective Feb. 17, 1989) replaced § 1391(c)’s incorporated, licensed, or doing-business corporate residence test with a personal-jurisdiction test.

Section 1391(c) permits an action to be brought in a district where a corporation is licensed to do and is doing business.

Farbenfabriken Bayer A.G. v. National Distillers & Chemical Corp. · filed 1971-03-18(c)

It is not denied that this action “might have been brought” in the Southern District of Texas, where National is licensed to do and is doing business, 28 U.S.C. § 1391(c).
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Section 1391(c) permits a corporation to be sued in any district where it does business.

Scovill Manufacturing Co. v. Sunbeam Corporation · filed 1973-04-24(c)

Venue in a declaratory judgment action based on patent infringement is not covered by 28 U.S.C. § 1400(b), but rather is governed by the general venue statute 28 U.S.C. § 1391(c), which provides that a corporation may be sued in any district where it does business.
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Section 1391(d) permits an alien defendant to be sued in any district, including in an antitrust suit.

Norman's on the Waterfront v. West Indies Corp. · filed 1974-07-17(d)

The broad rationale for the decision leaves no room for argument that it is limited to the patent field. Therefore, because all of these movant defendants are aliens, venue in the district of the Virgin Islands is proper under Section 1391(d),.
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Section 1391(d) permits venue in a district when the defendant is an alien business entity.

Vergara v. Aeroflot" Soviet Airlines" · filed 1975-03-05(d)

There is little question that venue is proper in this district, as the defendant is an alien business entity.
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Section 1391(d) permits an alien to be sued in any district.

Centronics Data Computer Corp. v. Mannesmann, A. G. · filed 1977-06-10(d)

The defendants in this action are all aliens, and venue is properly in this court by virtue of 28 U.S.C. § 1391(d) which provides: “An alien may be sued in any district.”
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Section 1391(d) permits alien defendants to be sued in any district.

Transatlantic Cement, Inc. v. Lambert Freres Et Cie · filed 1978-04-19(d)

These objections, however, are not well taken. Since the defendants are aliens, they may be sued in any district. See 28 U.S.C. § 1391(d).
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Section 1391(d) permits an alien corporation to be sued in this judicial district.

General Aircraft Corp. v. Air America, Inc. · filed 1979-01-30(d)

It is undisputed that Air Asia is an alien corporation and as such, venue is proper in this judicial district under 28 U.S.C. § 1391(d) and by analogy to the holding of the United States Supreme Court in Brunette Machine Works, Ltd. v. Kockum Industries, Inc., 406 U.S. 706, 92 S.Ct. 1936, 32 L.Ed.2d 428 (1972).
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Law changed since Pub. L. 112-63 (effective Jan. 6, 2012) treats a lawfully admitted permanent resident as residing where domiciled rather than allowing suit in any district as an alien.

Section 1391(d) permits a resident alien to be sued in any district.

Expotrade, Ltd. v. Dominguez · filed 1979-05-03(d)

As a resident alien, defendant may be sued in any district. 28 U.S.C. § 1391(d) (1976).
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Section 1391(d) permits an alien corporation to be sued in any district and supplements the Clayton Act’s venue provision in antitrust actions.

General Electric Co. v. Bucyrus-Erie Co. · filed 1982-10-22(d)

For the foregoing reasons, we read 28 U.S.C. § 1391(d) (1976) as supplemental to the venue provision embodied in section 12 of the Clayton Act, 15 U.S.C. § 22 (1976).
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Section 1391(d) does not provide venue where service of process cannot be obtained in the district, and it need not be used when the federal claims have special venue provisions.

Pioneer Properties, Inc. v. Martin · filed 1983-03-03(d)

Defendants refer the court to plaintiff’s complaint which alleges venue under 28 U.S.C. § 1391(d). Defendants argue that the doctrine is applicable since the requirement that venue be determined by a general venue statute is met by the complaint’s reference to § 1391(d). This argument is meritless. This statutory provision is inappropriate in view of the fact service of process could not be obtained in this district. Moreover, reliance on a general venue statute is unnecessary where plaintiff states claims based on federal laws which contain special venue provisions.
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Section 1391(d) permits an alien corporation to be sued in any district, including in a patent infringement action.

Brunswick Corp. v. Suzuki Motor Co., Ltd. · filed 1983-11-30(d)

Suzuki Motor is an alien corporation which, under 28 U.S.C. § 1391(d), “may be sued in any district.” Section 1391(d) applies to all federal actions against aliens, including patent infringement suits.
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Section 1391 permits venue where a corporate defendant does business and allows an alien to be sued in any district.

Ohio Reinsurance Corp. v. British National Insurance · filed 1984-04-27(c), (d)

This case is properly in the Southern District of New York both because defendants are doing business in New York, 28 U.S.C. § 1391(c), and because an alien may be sued in any district, 28 U.S.C. § 1391(d).
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Section 1391(d) permits an alien defendant to be sued in any district.

Totalplan Corp. of America v. Lure Camera Ltd. · filed 1985-01-31(d)

Alternatively, as it is alleged in the Complaints and not controverted by movants that Chwelos and Meiklejohn are residents and citizens of Canada and that Northwest Pipe is a Canadian corporation located in Canada, I hold that venue is proper here pursuant to 28 U.S.C. § 1391(d), which provides that “[a]n alien may be sued in any district.”
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Section 1391(d) makes venue proper for a suit against an alien corporation.

Beloit Corp. v. JM Voith, GmbH · filed 1986-01-16(d)

Venue with respect to Voith, an alien corporation, is proper pursuant to 28 U.S.C. § 1391(d).
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Section 1391(d) permits an alien defendant to be sued in any district.

Diatronics, Inc. v. Elbit Computers, Ltd. · filed 1986-07-16(d)

Since the defendant is an alien, however, the defendant may be sued in any district. See 28 U.S.C. § 1391(d). Thus, venue is proper.
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Section 1391(d) permits an alien corporation to be sued in any district, including when process is served under the Clayton Act.

Go-Video, Inc. v. Akai Electric Company, Ltd., and Matsushita Electric Industrial Company, Ltd. · filed 1989-09-05(d)

Go-Video was entitled to serve process under 15 U.S.C. § 22, even while seeking to satisfy venue under 28 U.S.C. § 1391(d). Venue, under § 1391(d), was proper in the District of Arizona.
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Section 1391(d) permits an alien defendant to be sued in any district where the court has personal jurisdiction.

Universal Security Instruments, Inc. v. Wing Wah Chong Investment Co. · filed 1990-02-05(d)

Defendant’s argument concerning the lack of venue is without merit. Wing Wah, a foreign corporation with offices in Hong Kong, can be subject to a civil action in any district in this country. This fact is self evident in 28 U.S.C. § 1391(d) which provides, “an alien may be sued in any district.” Therefore, if a proper basis of personal jurisdiction over Wing Wah exists, venue in this district is proper.
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Section 1391(d) permits an alien defendant to be sued in any district.

Presidential Motor Yacht, Corp. v. President Marine Ltd. · filed 1990-11-29(d)

Jurisdiction in the District Court for the District of Columbia is proper because an alien may be sued in any district. 28 U.S.C. § 1391(d).
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Section 1391(d) permits an alien to be sued in any district.

In Re RMR Corp. · filed 1991-07-16(d)

The "applicable nonbankruptcy" provision is found under 28 U.S.C. § 1391(d) which provides that an alien may be sued in any district.
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Section 1391(d) permits an alien to be sued in any district.

R.M.R. Corp. v. Clare Bros. (In re R.M.R. Corp.) · filed 1991-07-16(d)

The “applicable nonbankruptcy” provision is found under 28 U.S.C. § 1391(d) which provides that an alien may be sued in any district.
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Section 1391(d) permits an alien corporation to be sued in any district where it is amenable to service of process.

Naegler v. Nissan Motor Co., Ltd. · filed 1993-10-20(d)

Implicit in section 1391(d) and consistent with the cases interpreting it is the understanding that, for purposes of venue, an alien corporation may be sued in any district so long as it is properly amenable to service of process in that district.
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Section 1391(d) permits an alien to be sued in any district.

Modern Computer Corp. v. Ma · filed 1994-09-23(d)

First, venue is proper in this district under section 1391(d) because Ma is an alien.
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Section 1391(d) permits an alien to be sued in any district.

FFOC Co. v. Invent A.G. · filed 1994-11-21(d)

In response, Plaintiffs correctly assert that venue is proper in this district under § 1391(d) because an alien can be sued in any district.
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Section 1391(d) allows suit against an alien defendant in any district.

Miller Pipeline Corp. v. British Gas Plc · filed 1995-10-10(d)

Section 1406(a) does not apply in this ease because, as discussed above, venue is properly laid in this District pursuant to 28 U.S.C. § 1391(d). In fact, because section 1391(d) provides that an alien may be sued in any district, it appears that section 1406(a) would most likely never support transfer of a case against an alien defendant.
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Section 1391(d) permits suit against an alien in any district; when an alien is joined with a non-alien defendant, venue must also be proper as to the non-alien defendant.

Perez v. Pan Amer Life Ins Co · filed 1995-10-24(d)

As long as Pan American was joined as a defendant, venue was proper only in those districts where venue is proper as to the non-alien defendant, that is, Pan American. Once Pan American was dismissed, there was no bar to venue in the Southern District of Texas as to Seguros.
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Section 1391(d) permits an alien to be sued in any district, including in an action under the False Claims Act.

United States Ex Rel. Thistlethwaite v. Dowty Woodville Polymer, Ltd. · filed 1997-08-26(d)

In this case, venue is appropriately laid in this district because defendants are aliens. Under the Alien Venue Act, “[A]n alien may be sued in any district.” 28 U.S.C. § 1391(d). That Act applies even in view of the venue provision in section 3732.
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Section 1391(d) permits an alien defendant to be sued in any federal judicial district, even when a special venue statute would otherwise restrict venue.

Dee-K Enterprises, Inc. v. Heveafil Sdn. Bhd. · filed 1997-10-23(d)

Thus, § 1391(d) eliminates any venue impediment to suit in this district with respect' to the foreign defendants because they, as aliens, may be sued in any federal judicial district.
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Section 1391(d) permits an alien to be sued in any district, including in a patent infringement action.

Molnlycke Health Care AB v. Dumex Medical Surgical Products Ltd. · filed 1999-09-07(d)

The court agrees with plaintiff that the alien venue statute governs this action. This statute states that an “alien may be sued in any district.”
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Section 1391(d) permits an alien defendant to be sued in any judicial district, even if the defendant resides in a particular state.

McRae's, Inc. v. Hussain · filed 2000-06-30(d)

Since Hussain is a citizen of Pakistan, venue is proper in claims asserted against him in any judicial district in the United States, regardless of the fact that he has a residence in New Jersey.
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Section 1391(d) permits an alien to be sued in any district, but venue proper for the alien alone does not establish venue for other RICO defendants under § 1965(b).

Gatz v. Ponsoldt · filed 2003-07-07(d)

Because section 1391(d) allows aliens to be sued in any judicial district and Statesman is a Bahamian corporation with its principal place of business in Nassau, the Bahamas, it may be sued in any district, including the District of Nebraska. ... Therefore, the fact that Nebraska is a proper venue for Plaintiffs’ claims against Statesman pursuant to 28 U.S.C. § 1391(d) does not create proper venue for Plaintiffs’ claims against the remaining defendants under 18 U.S.C. § 1965(b).
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Section 1391(d) permits suit against an alien corporation in any federal district, subject to service of process.

In Re: Automotive Refinishing Paint Antitrust Litigation Basf Ag and Basf Coatings Ag · filed 2004-02-13(d)

Rather, Section 1391(d) derives from a tradition going “back to the beginning of the Republic” under which “suits against aliens were left unrestricted, and could be tried in any district, subject only to the requirement of service of process.”
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Section 1391(d) permits an alien corporation to be sued in any district.

Hall v. Tyco International Ltd. · filed 2004-07-27(d)

Because Tyco International is an alien, venue is proper in any district, including the Middle District of North Carolina.
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Section 1391(d) permits an alien defendant to be sued in any district.

Rabbi Jacob Joseph School v. Province of Mendoza · filed 2004-10-25(d)

Under 28 U.S.C. § 1391(d), "an alien may be sued in any district.” Accordingly, since the Province is an alien, RJJS could have sued the Province in the Southern District of New York, the transferee district.
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Section 1391(d) permits an alien to be sued in any district.

Sisso v. Islamic Republic of Iran · filed 2006-08-23(d)

Furthermore, there is no venue concern with respect to the claims against Hamas, because “[a]n alien may be sued in any district,” 28 U.S.C. § 1391(d), and, in any event, as noted above, properly served defendants who fail to appear waive any objections to venue.
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Section 1391(d) permits an alien defendant to be sued in any district.

Lizarbe v. Rondon · filed 2009-02-26(d)

Additionally, as a citizen of Peru, Rivera Rondon is an alien as to whom venue is proper in any district of Plaintiffs’ choosing.
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Section 1391(d) permits an alien corporation to be sued in any district, subject to personal jurisdiction.

Belden Technologies, Inc. v. LS CORP. · filed 2009-06-17(d)

The issue, therefore, becomes whether a finding of personal jurisdiction over a foreign defendant is a preliminary requirement to § 1391(d)’s provision that an alien may be sued in any judicial district. ... Therefore, the court finds that venue hinges on the resolution of the personal jurisdiction question.
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Section 1391(d) permits an alien to be sued in any district.

Constellation Energy Commodities Group Inc. v. Transfield ER Cape Ltd. · filed 2011-07-29(d)

Quite simply, the federal venue statute provides that “[a]n alien may be sued in any district.” 28 U.S.C. § 1391(d). Thus, because ER Cape is an alien, it may be sued in the Southern District of New York.
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Under the pre-2011 version of § 1391(d), an alien could be sued in any judicial district.

Kiwanuka v. Bakilana · filed 2012-02-24(d)

However, as plaintiffs point out, neither defendant is a United States citizen, and “[a]n alien may be sued in any district.” 28 U.S.C. § 1391(d) (2002). ... The Court therefore finds the plaintiff’s choice of forum to be proper and denies the defendants’ motion to dismiss on the basis of Rule 12(b)(3).
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Section 1391(c)(3) permits venue as to alien defendants.

Commodity Futures Trading Commission v. Aipu Limited · filed 2025-05-22(c)(3)

Venue also properly lies as to aliens Bai, Li, FIL, and Aipu pursuant to 28 U.S.C. § 1391(c)(3).
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Section 1391(d) permits an alien corporation to be sued in any district, including in a Sherman Act case.

Edward J. Moriarty & Co. v. General Tire & Rubber Co. · filed 1967-12-08(d)

It need only be noted that the special venue statute in question, 15 U.S.C. § 22, gives no indication that it is to be applied exclusively. Looking to the general venue statute, then, part (d) of § 1391 states simply: “An alien may be sued in any district.”
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Venue where a plaintiff resides when no real property is involved

Section 1391(e) permits venue in a district where any plaintiff resides in a suit against federal agencies or officials involving no real property.

Rohani v. Blinken · filed 2025-05-27(e)

The Court finds that venue is proper because two of the Plaintiffs reside in this district.
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Section 1391(e)(4) permits venue where a plaintiff resides when real property is only peripheral to the dispute; the exception applies when the dispute centers directly on the property.

Jewish War Veterans of the United States v. United States · filed 1987-10-23(e)(4)

It is clear, then, that Congress did not intend to constrict a plaintiff's choice of venue under 28 U.S.C. § 1391(e)(4) in all cases which even peripherally involve real property. Rather, a plaintiff cannot rest venue in his place of residence only in those disputes which “center directly on the real property, as with actions concerning the right, title or interest in real property.”
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An action seeking issuance of oil and gas leases involves real property, so the plaintiff’s residence does not establish venue under § 1391(e)(4).

Landis v. Watt · filed 1981-03-23(e)(4)

The Plaintiffs do want the court to order the issuance of oil and gas leases, and both the legislative history and the Ashley case support the proposition that real property is involved and venue in Idaho is improper.
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Section 1391(e)(4) permits venue in the plaintiff’s district of residence when real property is only peripherally involved in the action.

Ashley v. Andrus · filed 1979-08-16(e)(4)

Therefore, this Court must find that real property is not involved in the sense intended by 28 U.S.C. § 1391(e)(4), and, therefore, plaintiff is entitled to bring this action in the district in which she resides.
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Section 1391(e) permits multiple plaintiffs to bring an action in a district where at least one plaintiff resides, even if the others do not.

Exxon Corp. v. Federal Trade Commission · filed 1978-12-07(e)

There is no requirement that all plaintiffs reside in the forum district.
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Section 1391(e)(4) permits venue based on the residence of one plaintiff when no real property is involved, even if other plaintiffs live elsewhere.

Dow Chemical v. Consumer Product Safety Commission · filed 1978-11-01(e)(4)

The term “plaintiff” as used in subsection (4) of section 1391(e) relating to venue where no real property is involved means a plaintiff rather than all the plaintiffs.
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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 venue in the district where the plaintiff resides.

In Re Air Crash Disaster at John F. Kennedy International Airport · filed 1978-12-01(a)

Since the plaintiffs involved in the immediate remand motions reside in the respective districts to which they seek a transfer, venue would be proper. 28 U.S.C. § 1391(a) (1976).
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Section 1391(e)(4) permits venue where a plaintiff resides when no real property is involved in the action.

Environmental Defense Fund, Inc. v. Corps of Engineers of the U. S. ARMY · filed 1971-01-21(e)(4)

The Court is of the opinion that this is not an action in which “real property is involved” in the sense contemplaetd by § 1391(e) (4). There is nothing that needs to be done to accomplish the objectives of the plaintiffs which can not be as readily done by this Court as that which could be done by, say, the District Court in Washington, D. C., had the plaintiffs filed there as permitted by § 1391. Indeed, if the plaintiffs here were limited to individual citizens residing in the Eastern District of Arkansas, it is very doubtful, in the Court’s opinion, that venue would lie in the Western District because no “real property involved in the action,” under the Court’s analysis, is situated there. Nothing needs to be done in this action with respect to the real estate under and adjacent to the Cossatot or upon which defendants contemplate constructing the Gillham Dam. The action does not put in issue the title to, or possession of, such lands, or any interest therein.
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Section 1391(e)(4) permits venue where the plaintiff resides when real property is affected only peripherally by the action.

State of Delaware v. Bender · filed 1974-01-28(e)(4)

While the decision may determine whether or in what manner the Sharp-town bridge will be constructed, real estate will be involved only peripherally. This was not the type of involvement that § 1391(e)(4) was intended to cover. Venue in this district is proper.
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Section 1391(e)(4) does not allow venue based on the plaintiff’s residence when the action seeks steps toward acquiring an interest in public land, because such an action involves real property.

Ferguson v. Lieurance · filed 1983-06-28(e)(4)

The proposition that an action for declaratory relief to hold void and unenforceable any statutes, rules, regulations or practices which prescribe essential preliminary steps or procedures to initiate entry on the public lands of the United States under the public land laws is not an action involving real property is a legal sophistry. The obvious and undeniable purpose of such an action is to place the public officials in a position which will require them to accept applications, issue permits, grant entry, or whatever, to the end that plaintiff will acquire the real property interest he seeks. Such an action does involve real property.
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Section 1391(e)(4) permits venue where a plaintiff resides when a challenge to a federal official’s lease eligibility decision does not concern particular local land, even if the decision affects oil and gas leases.

Santa Fe International Corp. v. Watt · filed 1984-02-01(e)(4)

When measured against the legislative history of section 1391(e), I conclude that the instant litigation does not involve real property for venue purposes.
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Section 1391(e)(3) permits suit in the plaintiff’s home district when real property is not substantially involved in the action.

Shell Oil Co. v. Babbitt · filed 1996-03-13(e)(3)

However, because the central issue in this case involves review of an administrative order to produce documents relating to the valuation of personal property, the Court holds that real property is not involved in this action for purposes of 28 U.S.C. § 1391(e). Accordingly, because Shell Oil is incorporated in Delaware, venue is proper in this judicial district under 28 U.S.C. § 1391(e)(3).
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Section 1391(e)(3) permits venue in a district where any one plaintiff resides when multiple plaintiffs sue a federal officer or agency and no real property is involved.

Sidney Coal Co., Inc. v. Massanari · filed 2002-09-05(e)(3)

Thus, under 28 U.S.C. § 1391(e), this Court concludes that a suit can be brought in a district in which a single plaintiff resides.
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Section 1391(e)(3) permits a state suing the federal government to bring suit in any federal judicial district within its borders.

Alabama v. United States Army Corps of Engineers · filed 2005-08-10(e)(3)

Therefore, the court holds that a state may bring suit under 28 U.S.C. § 1391(e)(3) in any district within the state, and that venue is, therefore, proper as to Alabama’s claims in this case.
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Section 1391(e)(3)’s residency requirement is satisfied when at least one plaintiff resides in the district where the action is brought.

Sidney Coal Co Inc v. Social Sec Admin · filed 2005-10-19(e)(3)

In sum, the case law and legislative history compel this Court to hold that the residency requirement of 28 U.S.C. § 1391(e)(3) is satisfied if at least one plaintiff resides in the district in which the action has been brought.
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Section 1391(e)(3) permits venue in a district where at least one plaintiff resides, even if other plaintiffs reside elsewhere.

Sidney Coal Company, Inc. v. Social Security Administration, (04-6286), Michael H. Holland, Intervenors (04-6291) · filed 2005-10-19(e)(3)

The statute’s legislative history and the plethora of case law interpreting the statute, taken together, persuade this Court that § 1391(e)(3) contains no requirement that all plaintiffs must reside in the same district.
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Section 1391(e)(3) permits venue for all plaintiffs in a suit against the United States when at least one plaintiff resides in the district and no real property is involved.

Matsuo v. United States · filed 2006-02-21(e)(3)

With respect to the third prong, in a multi-plaintiff suit, only one plaintiff must reside in the district for venue to be proper as to all plaintiffs. ... Venue in the District of Hawaii therefore is appropriate for all Plaintiffs under § 1391(e)(3).
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Section 1391(e) permits an action against a federal agency or official in the district where the plaintiff resides if no real property is involved.

Detroit International Bridge Co. v. Federal Highway Administration · filed 2009-10-13(e)

Additionally, the general statute governing venue allows civil actions against “an officer or employee of the United States or any agency thereof acting in,his official capacity or under color of legal authority, or an agency of the United States” to be brought in any judicial district in which “the plaintiff resides if no real property is involved in the action.” 28 U.S.C. § 1391(e). DIBC “resides” in the Eastern District of Michigan.
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Section 1391(e)(1)(C) permits venue where a plaintiff resides when the action does not involve real property; a challenge to forest projects without a dispute over real property interests meets that condition.

Earth Island Institute v. Quinn · filed 2014-07-21(e)(1)(C)

Therefore, the court finds that Plaintiffs have met their burden to demonstrate that venue is permissible in this district, since Plaintiffs reside in this district and the action does not “involve real property” within the meaning of 28 U.S.C. § 1391(e)(1)(C).
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Section 1391(e)(3) permits venue where the plaintiff resides in a suit against a federal agency when no real property is involved.

Western Watersheds Project v. Interior Board of Land Appeals · filed 2019-08-16(e)(3)

WWP “resides” in the District of Idaho, and the Court has ruled previously that cases similar to this do not involve real property as that term is used in the statute. ... The Court reaffirms its holdings in those cases and finds that venue is proper here.
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Section 1391(e)(1)(C) permits a plaintiff to sue federal defendants where the plaintiff resides when the action challenges agency compliance with statutory duties without disputing rights or interests in real property.

Western Watersheds Project v. Schneider · filed 2019-10-02(e)(1)(C)

Because “real property” is not “involved” as those terms are used in the venue statute, the Court finds that venue is proper here under § 1391(e)(1)(C).
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Section 1391(e)(1)(C) permits venue where a plaintiff resides when a challenge to a general land management plan disputes no interest in real property.

Western Organization of Resource Councils v. United States Bureau of Land Management · filed 2021-02-24(e)(1)(C)

The legislative history of the venue statute confirms a reading that general land management plans do not involve real property for venue purposes.
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In a suit against federal officials, § 1391(e)(1) permits venue in the judicial district where the plaintiff resides.

Gorrepati v. Wolf · filed 2021-02-25(e)(1)

Venue would be proper in this case “in any judicial 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 (C) the plaintiff resides.” 28 U.S.C. § 1391(e)(1) (emphasis added). Plaintiffs both reside in De Pere, Wisconsin, which is located within the Eastern District of Wisconsin.
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Section 1391(e)(1)(A) permits venue in a district where a defendant federal official resides.

Koratala v. Gaynor · filed 2021-03-02(e)(1)(A)

Ms. Zuchowski’s status as a resident of Vermont supplies another basis for venue in the District of Vermont. See 28 U.S.C. § 1391(e)(1)(A).
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Section 1391(e)(1)(C) permits an action against a federal agency to be brought where the plaintiff resides when no real property is involved.

Zhao v. United States Citizenship and Immigration Services · filed 2021-04-07(e)(1)(C)

Accordingly, venue lies in the Eastern District of New York, see § 1391(e)(1)(C), and the Court therefore transfers this action to the Eastern District of New York, see 28 U.S.C. § 1406(a).
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Section 1391(e)(1)(C) permits venue where the plaintiff resides in an action against a federal agency when no real property is involved.

Doyle v. The Department of Veteran Affairs · filed 2021-10-15(e)(1)(C)

Under subsection (e)(1)(C), venue would also be proper as to the WPA claim in the District of Maryland: this case involves no real property and it is undisputed that plaintiff resides in Maryland.
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In an action against a federal officer or agency involving no real property, § 1391(e)(1)(C) permits venue where the plaintiff resides.

Defender Services, Inc. v. Mayorkas · filed 2022-03-29(e)(1)(C)

Therefore, because Plaintiff resides in the Transferee District, this case “might have been brought” in that district for purposes of the federal change of venue statute. 28 U.S.C. § 1404(a); see also 28 U.S.C. § 1391(e)(1)(C).
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Section 1391(e)(1)(C) permits venue where a plaintiff resides if the action does not center directly on rights in real property, even when the remedy may affect property interests.

Montana Wildlife Federation v. Bernhardt · filed 2022-07-05(e)(1)(C)

The Court’s remedy may or may not affect individual oil and gas leases, but that fact does not convert an administrative challenge over federal land management into a real property dispute. Venue is thus also proper in the District of Montana under Section 1391(e)(1)(C) of Title 28.
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Section 1391(e)(1)(C) permits a civil action against a federal agency to be brought where the plaintiff resides if no real property is involved.

Hale v. Collis · filed 2023-04-03(e)(1)(C)

Where the defendant in a civil action is an agency of the United States, venue is appropriate in “any judicial 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 (C) the plaintiff resides if no real property is involved in the action.” 28 U.S.C. § 1391(e)(1); see also id. (applying to officers or employees of these agencies). As Hale resides in Southern Illinois and no real property is involved, venue is proper there.
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Section 1391(e)(1)(C) permits a suit against a federal agency in a district where at least one plaintiff resides when no real property is involved, unless another law provides a different venue rule.

National Republican Senatorial Committee v. Federal Election Commission · filed 2023-05-09(e)(1)(C)

And as Plaintiffs correctly point out, “§ 1391(e)’s residency requirement is satisfied as long as ‘at least one plaintiff resides in the district in which the action has been brought.’” ... So long as no other venue statute trumps, venue is appropriate in this District.
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Section 1391(e)(1)(C) permits venue where the plaintiff resides in a suit against a federal officer, employee, or agency if no real property is involved.

Kaff v. United States Department of Homeland Security · filed 2023-11-21(e)(1)(C)

Venue is proper under 28 U.S.C. § 1391(e)(1)(C) in the District of New Jersey.
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Section 1391(e)(1) permits venue where the plaintiff resides when a defendant is a federal officer or employee acting in an official capacity and the suit does not involve real property.

Fenton v. Story · filed 2024-01-25(e)(1)

Section 1391(e)(1) provides an exception permitting the plaintiff to file the lawsuit where the plaintiff resides, but only when a defendant is an officer or employee of the United States acting in his or her official capacity and the lawsuit does not involve real property. The exception does not apply here.
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Section 1391(e)(1) permits venue in a suit against a federal agency where a plaintiff resides; dismissal of the only plaintiff residing in the district can leave venue improper.

Dayton Area Chamber of Commerce v. Becerra · filed 2024-08-08(e)(1)

To determine whether venue is proper, courts look to 28 U.S.C. § 1391. Section 1391(e)(1) states that, when a government agency is the defendant, venue is proper “in any judicial district in which […] the plaintiff resides if no real property is involved in the action.” ... Because the Court has determined that the Dayton Area Chamber must be dismissed due to lack of standing, venue is no longer proper in the Western Division of the Southern District of Ohio.
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Section 1391(e)(1)(C) permits venue in the plaintiff’s district of residence for a suit against federal officers or agencies when no real property is involved.

Rabelo v. Mayorkas · filed 2025-11-13(e)(1)(C)

This suit could have been brought in the District of Utah because Ms. Rabelo resides in Utah and the case does not involve real property.
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Section 1391(e)(1)(C) permits venue where a plaintiff resides only if no real property is involved; an action seeking to invalidate oil and gas lease sales involves real property.

Zinke · filed 2025-12-23(e)(1)(C)

Accordingly, the Court finds that the at-issue oil and gas lease sales are real property “involved” in the instant action and that venue does not lie in the District of Idaho under § 1391(e)(1)(C).
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General venue provisions

Section 1391(b) governs venue in SOX whistleblower suits because SOX has no exclusive venue provision.

GULDEN v. EXXON MOBIL CORPORATION · filed 2025-05-30(b)

Here, the Court finds that SOX does not have an exclusive venue provision that supersedes the general venue provisions in Section 1391(b).
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Section 1391(b) requires a statutory basis for venue; a plaintiff’s plan to move to the district does not supply one.

Greene v. United States · filed 2025-05-28(b)

They appear to be suggesting that they will move to the Eastern District of Missouri so that venue will be proper. The Court is unpersuaded by Plaintiff's motion. Plaintiffs reside in California and admit that the alleged conduct for which they brought suit “occurred in another state.” ECF No. 5 at 3. None of the venue requirements of 28 U.S.C. § 1391(b) are present in this case.
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Section 1391(b) does not provide venue in a district when the claims arise from events in another district and the defendants are located there.

Hill et ux v. Harry · filed 2021-09-08(b)

Accordingly, because there is no apparent basis for venue for these claims in this district, and because Defendants Sorber, Bradley, Terra, and Stenkowski are located there, the Court will transfer Mr. Hill’s claims against these Defendants to the United States District Court for the Eastern District of Pennsylvania.
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Section 1391(b)(1) and (2) permits venue where a defendant resides or a substantial part of the events giving rise to the claim occurred.

Boyd v. LaGuardia Airport · filed 2021-09-01(b)(1), (b)(2)

Because Plaintiff does not allege that any defendant resides in this district or that a substantial part of the events or omissions giving rise to his claim arose in this district, venue is not proper in this Court under § 1391(b)(1), (2).
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Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred or a substantial part of the property at issue is situated.

Brigade Holdings, Inc. v. Aegis Business Credit, LLC · filed 2021-08-26(b)(2)

A substantial part of the events giving rise to the claims in this case occurred in Maryland, and the case is centered around rights to property in Maryland. Therefore, venue is proper in the District of Maryland.
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Section 1391(b)(1) and (2) makes venue improper where no defendant resides and no substantial part of the events or omissions giving rise to the claim occurred.

McIntyre v. Pardon · filed 2021-08-23(b)(1), (2)

Because Plaintiff does not allege that any defendant resides in this district or that a substantial part of the events or omissions giving rise to her claims arose in this district, venue is not proper in this Court under § 1391(b)(1), (2).
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Section 1391(b)(1) and (2) do not permit venue in a district where no defendant resides and no substantial part of the events giving rise to the claim occurred.

Daverne v. Barbioni · filed 2021-08-25(b)(1), (b)(2)

Because Plaintiff does not allege that any defendant resides in this district or that a substantial part of the events or omissions giving rise to his claims arose in this district, venue is not proper in this Court under § 1391(b)(1), (2).
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Section 1391(b)(1) and (2) permits venue where a defendant resides, if all defendants reside in the same state, or where a substantial part of the events or omissions giving rise to the claim occurred.

Rushing v. Meyers Groceries Stores, Inc. · filed 2021-08-17(b)(1), (b)(2)

Plaintiff does not allege that a substantial part of the events or omissions underlying his claims arose in this District. Venue is therefore not proper in this Court under § 1391(b)(1) or (2).
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Section 1391(b) does not provide venue in Massachusetts for civil claims against employees of a Mississippi correctional facility.

Strain v. Tallahatchie County Correctional Facility employee · filed 2021-08-30(b)

To the extent that Strain is attempting to bring civil claims against employees of the Tallahatchi County Correctional Facility, venue does not exist in the District of Massachusetts, see 28 U.S.C. § 1391(b), and the Court lacks personal jurisdiction over the defendants, see Int’l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945).
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Section 1391(b) permits venue where a defendant resides, subject to the state-residence requirement, or where a substantial part of the events giving rise to the claim occurred.

Nunez v. The Superintendent of Elmira Correctional Facility · filed 2021-07-20(b)(1), (b)(2)

Because Plaintiff does not allege that any defendant resides in this district or that a substantial part of the events or omissions giving rise to his claim arose in this district, venue is not proper in this Court under § 1391(b)(1), (2).
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Section 1391(b)(1) permits venue in a district where a defendant resides if all defendants reside in that district’s state.

Wiersum v. Chakroff · filed 2021-07-23(b)(1)

Plaintiff does not allege that Defendant resides in this District, so venue is not proper in this Court under § 1391(b)(1).
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Section 1391(b) permits a civil action in a district where any defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred.

Gardiner 383334 v. Corizon Health, Inc. · filed 2021-07-20(b)

Relevant here, 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. ... Because there is no apparent basis for venue to lie in this district, but there are facts in the complaint suggesting that venue would be proper in the Western District, the Court finds that the interests of justice would be served by transferring the case to the district where it should have been filed in the first instance.
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Section 1391(b)(1) and (2) permit venue where the defendants reside or where a substantial part of the events giving rise to the claim occurred.

Bunion v. Thomas · filed 2021-07-16(b)(1), (b)(2)

Rather, venue is proper under both § 1391(b)(1) and (2) in the Northern District of Georgia, where Defendants likely reside and the events giving rise to the claims occurred.
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Section 1391(c) provides the general venue rules for federal district courts and applies to an Equal Pay Act cause of action here.

Laffey v. Northwest Airlines, Inc. · filed 1971-02-11(c)

Because the principal cause of action, as this Court views it, is under the Equal Pay Act, the general venue provisions for federal district courts, 28 U.S.C. § 1391(c) (Supp.1966), should apply; and venue in the District of Columbia is appropriate for this Equal Pay Act cause of action.
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Section 1391's general venue provisions do not apply when venue is governed by the Securities Exchange Act and jurisdiction is not based on diversity of citizenship.

McAdoo v. Union National Bank of Little Rock · filed 1977-07-07

Jurisdiction has never been based on diversity of citizenship, and the general venue provisions of 28 U.S.C. § 1391 are not applicable to the case.
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Section 1391's general venue provisions do not apply when venue is governed by the Securities Exchange Act's venue provision.

Mcadoo v. Union National Bank Of Little Rock · filed 1977-08-25

Jurisdiction was based on the Act and venue was laid under the provisions of 15 U.S.C. § 78aa. Jurisdiction has never been based on diversity of citizenship, and the general venue provisions of 28 U.S.C. § 1391 are not applicable to the case.
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Notes 2251–2400 of 8,639, oldest cases first.

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