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No reviewed case has held this section invalid, preempted, superseded or repealed.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 for suits against foreign states

Section 1391(f) governs venue in actions against foreign states and their agencies; venue is improper in a district where none of its listed grounds applies.

Coastal Mechanics Co. v. Defense Acquisition Program Administration · filed 2015-01-13(f)

Therefore, the appropriate venue subsection governing this case is 28 U.S.C. § 1391(f). ... None of these subsections apply here. ... Therefore, venue in the Eastern District of Virginia is improper.
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Section 1391(f)(1) requires a substantial part of the events giving rise to a claim against a foreign state to occur in the district; online access to allegedly infringing material alone does not establish venue.

Pablo Star Ltd. v. Welsh Government · filed 2016-03-16(f)(1)

But the fact that an infringing material is accessible via the internet in a jurisdiction is hardly sufficient to conclude that this infringement occurred in this district for the purposes of venue.
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Section 1391(f) requires proper venue for an action to enforce an ICSID award against a foreign sovereign.

Mobil Cerro Negro, Ltd. v. Bolivarian Republic of Venezuela · filed 2017-07-11(f)

As a result, when the ICSID award-debtor is a foreign sovereign, the FSIA’s procedural mandates control, including the requirements that process be served to obtain personal jurisdiction under 28 U.S.C. § 1330(b), and venue be proper under 28 U.S.C. § 1391(f).
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Section 1391(f) permits venue in an action against a foreign state where a substantial part of the relevant events occurred or the property at issue is situated.

Micula v. Government of Romania · filed 2017-10-23(f)

As to Romania's second argument, we also agree that the Southern District of New York is an improper venue under the FSIA, at least on this record. The Petitioners' ex parte petition is devoid of any assertion that New York is the appropriate venue under the FSIA. It is also unclear from the face of the petition that there is any conduct connecting this action to New York. The parties are foreign, the arbitration hearings were conducted in Paris, and the property at issue was located in Romania.
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Section 1391(f)(3) applies to actions against a foreign state’s agency or instrumentality; subsection (f)(4) applies to actions against the foreign state itself.

Cummings v. Islamic Republic of Iran · filed 2019-12-30(f)

Therefore, section 1391(f)(3), which applies to actions “against an agency or instrumentality of a ... foreign state,” does not apply. Instead, section 1391(f)(4) applies, because this is an action ... “against a foreign state.” Accordingly, the United States District Court for the District of ... Columbia is the proper venue for this action.
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Section 1391(c)(3) treats a foreign state as a nonresident defendant and disregards it when determining venue for other defendants; an embassy does not make the state a resident of that district.

Wells Fargo Bank, N.A. v. Caballero · filed 2020-02-25(c)(3)

Here, Honduras is not a resident of the United States because it is a foreign state. The fact that Honduras has an embassy in the District of Columbia does not mean it resides there. Under § 1391(c), Honduras is disregarded in determining where the action may be brought.
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Section 1391(f)(4) permits a civil action against a foreign state to be brought in the District of Columbia.

Foresight Luxembourg Solar 1 S.A.R.L. v. Kingdom of Spain · filed 2020-03-30(f)(4)

Section 1394(f)(4) does apply because this lawsuit is against a foreign state and Congress has designated the District of Columbia as the “dedicated venue” for civil cases involv- ing foreign states.
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Section 1391(f) permits a suit against a foreign state, including its embassy, in the District of Columbia or in a district where a substantial part of the events occurred.

McGee v. Kingdom of Saudi Arabia · filed 2020-07-23(f)

Under this guidance, the Embassy of Saudi Arabia, like Saudi Arabia, is properly considered a “foreign state,” and venue would be appropriate in the District of Columbia pursuant to subsection (4) and in the Eastern District of Virginia under subsection (1).
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Section 1391(f)(4) permits venue in the District of Columbia for actions against foreign states and their political subdivisions, but not their instrumentalities.

Ogi Group Corporation v. Oil Projects Company of the Ministry of Oil, Baghdad, Iraq (Scop) · filed 2020-10-29(f)(4)

Accordingly, consistent with the plain statutory text read in its context, this court concludes that Section 1391(f)(4) is limited to a foreign state and its political subdivisions and does not apply to a foreign state’s instrumentalities.
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Section 1391(f)(1) requires a substantial part of the events giving rise to a claim against a foreign state to have occurred in the district; the plaintiff’s residence does not establish venue.

Holloway v. Holy See · filed 2021-05-05(f)(1)

Section 1391(f)(1) is explicit that proper venue lies where a substantial portion of the event giving rise to the claim took place, and thus plaintiff’s residence is irrelevant to the venue analysis.
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Section 1391(f)(4) permits a civil action against a foreign state or political subdivision in the District of Columbia.

D'Entreprise v. Republic of Guinea · filed 2021-06-14(f)(4)

Venue is proper because this action is against a foreign state.
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Section 1391(f)(3) requires evidence that a foreign state instrumentality is licensed to do business or does business in the district before venue lies there.

Henkin v. Islamic Republic of Iran · filed 2021-07-12(f)(3)

The explicit language of § 1391(f)(3) explains that a proper venue for an agency or instrumentality is “any judicial district in which the agency or instrumentality is licensed to do business or is doing business.” Contrary to the statutory requirements, Plaintiffs did not put forth evidence to carry their burden to show as a matter of fact that these banks are licensed to or do business in D.C. Thus, venue is not proper in D.C. for the banks. However, this does not require dismissal of the agency-or-instrumentality claims.
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Section 1391(f) exclusively governs venue in suits against foreign states, excluding the general venue rules in subsections (b) and (c).

Uni-Top Asia Investment Limited v. Sinopec International Petroleum Exploration and Production Corporation · filed 2022-04-22(f)

The text and structure of § 1391 make clear that venue for suits against foreign states is governed by § 1391(f), to the exclusion of § 1391(b) and § 1391(c).
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Section 1391(f) permits actions against foreign states in four specified venues; venue in the District of Columbia is not exclusive.

Espitia v. Islamic Republic of Iran · filed 2022-06-16(f)

But Section 1391(f) is permissive and not exclusive—i.e., a state action “may be brought” in four defined venues—and here, venue is proper in the Southern District of Texas, Brownsville Division.
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Section 1391(f) permits actions against foreign states in four specified venues without making any one of them exclusive.

Battles v. Islamic Republic of Iran · filed 2022-08-17(f)

But Section 1391(f) is permissive and not exclusive—i.e., a state action “may be brought” in four defined venues—and here, venue is proper in the Southern District of Texas, Brownsville Division.
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Section 1391(f) permits actions against foreign states in four defined venues; venue in the District of Columbia is not exclusive.

Herrick v. Islamic Republic of Iran · filed 2022-08-17(f)

But Section 1391(f) is permissive and not exclusive—i.e., a state action “may be brought” in four defined venues—and here, venue is proper in the Southern District of Texas, Brownsville Division.
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Section 1391(f)(4) permits a civil action against a foreign state to be brought in the District of Columbia.

Stearns v. Islamic Republic of Iran · filed 2022-10-03(f)(4)

For civil actions "against a foreign state or political subdivision thereof," venue is proper "in the United States District Court for the District of Columbia." 28 U.S.C. § 1391(f)(4). ... Since Iran is a foreign state, the Court concludes that venue is proper in this District.
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Section 1391(f)(4) permits a civil action against a foreign state or its political subdivision to be brought in the District of Columbia.

Ben-Yishai v. Syrian Arab Republic · filed 2022-11-28(f)(4)

For civil actions "against a foreign state or political subdivision thereof," venue is proper "in the United States District Court for the District of Columbia." 28 U.S.C. § 1391(f)(4). Iran and Syria are "foreign state[s]" as defined by Section 1603 of the FSIA. See 28 U.S.C. § 1603(a); Henkin v. Islamic Republic of Iran, No. 18-cv-1273 (RCL), 2021 WL 2914036, *4 (D.D.C. July 12, 2021). Since Syria and Iran are foreign states, the Court concludes that venue is proper in this District.
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Section 1391(f)(4) did not make the Southern District of Florida a proper venue for a claim against a foreign state.

Rodriguez v. Imperial Brands PLC · filed 2023-03-31(f)(4)

Venue is improper in the Southern District of Florida under 28 U.S.C. § 1391(f)(4), as that section provides for venue against a foreign state or political subdivision thereof in the District of Columbia; ... Based on its de novo review of the record, including the Report, Plaintiffs’ objections, and Defendants’ responses, this Court agrees with Judge Otazo-Reyes’s analysis and finding that venue is improper as to Habanos.
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Section 1391(e)(1) permits venue in a district where the plaintiff resides and a substantial part of the events giving rise to the claim occurred.

Radziewicz v. United States · filed 2023-07-25(e)(1)

Although plaintiff does not request transfer to any particular court, venue in the United States District Court for the District of Delaware is proper, because plaintiff resides in Delaware and a substantial part of the events giving rise to the claim occurred there.
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Section 1391(f)(4) permits an action against a foreign state or its political subdivision in the District of Columbia, which may be the only proper venue when the alleged events occurred abroad.

Dalbis v. Pubic Employees of Security and Intelligence Services of France and Europe · filed 2024-05-07(f)(4)

Because the United States District Court for the District of Columbia is the only venue in which Plaintiff can assert his Alien Tort Statute/TVPA claims against the National Gendarmerie and the individual defendants, the Court transfers this action to that court.
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Section 1391(f) permits actions against foreign states in four specified venues; the District of Columbia is not the exclusive venue.

Amrhein v. Islamic Republic of Iran · filed 2024-05-13(f)

But Section 1391(f) is permissive and not exclusive—i.e., a state action “may be brought” in four defined venues—and here, venue is proper in the Southern District of Texas, Brownsville Division.
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Section 1391(f) permits an action against a foreign state in any of four specified venues.

Stewart v. Islamic Republic of Iran · filed 2024-05-30(f)

But Section 1391(f) is permissive and not exclusive—i.e., a state action “may be brought” in four defined venues—and here, venue is proper in the Southern District of Texas, Brownsville Division.
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Section 1391(e)(1) permits venue in a suit against the United States where a defendant resides, a substantial part of the events occurred, or the plaintiff resides if no real property is involved.

WHITLOCK v. United States · filed 2024-08-12(e)(1)

Here, none of the conditions for venue in the Eastern District of Pennsylvania are present.
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Section 1391(f)(4) permits a civil action against a foreign state or its political subdivision to be brought in the District of Columbia.

Mills Law Group LLP v. Republic of Iraq · filed 2024-09-27(f)(4)

Venue is proper in the United States District Court for the District of Columbia for all civil actions “against a foreign state or political subdivision thereof.” 28 U.S.C. § 1391((4). As discussed, both Iraq and MoJ fall within the definition of a foreign state under FSIA. See 28 U.S.C. § 1603(a). Since Iraq and MoJ are both foreign states, the Court concludes that venue is proper in this district.
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Section 1391(f)(4) permits venue in the District of Columbia for a civil action against a foreign state or its political subdivision.

Baxter v. Islamic Republic of Iran · filed 2025-03-04(f)(4)

For civil actions "against a foreign state or political subdivision thereof," venue is proper “in the United States District Court for the District of Columbia.” 28 U.S.C. § 1391(f)(4). Syria is a foreign state and SAFI is a political subdivision as defined by the FSIA. Id. § 1603(a). Venue is therefore proper in this District.
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Section 1391(f)(4) makes venue proper in the District of Columbia for a civil action against a foreign state or its political subdivision.

Strauss v. Islamic Republic of Iran · filed 2025-03-07(f)(4)

For civil actions ‘against a foreign state or political subdivision thereof,’ venue is proper “in the United States District Court for the District of Columbia.” 28 U.S.C. § 1391(f)(4). Iran is a foreign state as defined by the FSIA. Jd. § 1603(a). Venue is therefore proper in this District.
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Section 1391(f) governs venue for suits against foreign states and allows such a suit in the District of Columbia even without a connection to another judicial district.

Chikhladze v. Tbilisi-Based Organized Group · filed 2025-05-05(f)

But the Government of the Kingdom of Denmark is a foreign state, which falls under § 1391(f). This subsection also requires a connection to the judicial district in the United States, which is not alleged here, unless the action is brought in the United States District Court for the District of Columbia.
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Section 1391(f)(4) makes the District of Columbia a proper venue for claims against a foreign state arising from events abroad.

Dalbis v. France (Administration, Public Services) · filed 2025-08-05(f)(4)

Because Dalbis’s claims against France arise from events that allegedly occurred in France, the only proper venue for those claims is the United States District Court for the District of Columbia. See 28 U.S.C. § 1391(f)(4).
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Section 1391(f)(4) designates the District of Columbia as a venue for suits against foreign states, a designation relevant to a forum non conveniens analysis.

Cruise Connections Charter Management 1, LP v. Attorney General of Canada · filed 2011-02-15(f)(4)

This case is in U.S. District Court for the District of Columbia because the FSIA gives U.S. plaintiffs a right to sue foreign governments in this jurisdiction when they are harmed by a foreign government’s role in commerce, see 28 U.S.C. § 1605(a)(2), ie., when it is not acting as sovereign, and this district is the designated forum for such actions. See 28 U.S.C. § 1391(f)(4) (U.S. District Court in the District of Columbia is the designated forum for FSIA claims against foreign states).
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Section 1391(f)(3) permits suit against a foreign state’s agency or instrumentality in a district where it is licensed to do business or is doing business.

Doe v. Etihad Airways, P.J.S.C. · filed 2017-08-30(f)(3)

But as a condition of Etihad’s Foreign Air Carrier Permit—issued by the United States Department of Transportation to permit Etihad to fly to United States airports—Etihad waived sovereign immunity from suit in United States courts and could thus be sued “in any judicial district in which [Etihad] is licensed to do business or is doing business,” which includes the Eastern District of Michigan because of Etihad’s codeshare and other business agreements with airlines operating from points within that district.
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Venue with multiple defendants

Section 1391(b) requires proper venue for indispensable defendants; a dispensable defendant whose presence defeats venue may be dismissed without dismissing the entire action.

Anrig v. Ringsby United · filed 1979-03-13(b)

In other words, if a non-resident, non-indispensable party is listed as a defendant, this will not automatically require dismissal of the entire action for lack of venue but, rather, the non-indispensable party should be dismissed out in order to preserve proper venue for the remaining indispensable defendants.
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Section 1391(b) applies its venue requirement to indispensable defendants; a nonresident dispensable defendant does not require dismissal of the entire action.

Anrig v. Ringsby United · filed 1978-11-13(b)

The error in the court’s reasoning is that Section 1391 cannot be read literally, but must be read to apply only to indispensable defendants.
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Section 1391(b) requires venue to be proper for each defendant when a plaintiff sues multiple defendants.

Textor v. Board of Regents of Northern Illinois University · filed 1980-10-02(b)

When a plaintiff sues multiple defendants as here, venue must be proper with respect to each defendant.
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Section 1391(b) requires venue to be established separately for each defendant in a conspiracy action; acts by a co-conspirator in the district do not establish venue for a defendant who committed no act there.

Vest v. Waring · filed 1983-05-31(b)

Thus, assuming arguendo that the “weight of the contacts” rests in the Northern District of Georgia, and that this district is in fact “where the claim arose,” this court must still satisfy itself that each defendant in this lawsuit committed overt acts pursuant to a conspiracy in this district, in order to find that venue is properly laid here.
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The court treated § 1391(b) as permitting venue in either district where a defendant resided when defendants lived in different districts of one state.

Al-Muhaymin v. Buttrini · filed 1988-10-07(b)

Where all defendants in a multi-district state reside within the state, but within different districts, venue is proper in any district where one or more defendants reside. See 28 U.S.C. Sec. 1391(b); Sinwell v. Shapp, 536 F.2d 15 (3d Cir.1976). Thus, venue would be proper in either the Middle or the Eastern District of Tennessee.
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Section 1391(a)(2) requires venue to be established as to each defendant, based on substantial events or omissions giving rise to the claim against that defendant.

Emjayco v. Morgan Stanley & Co., Inc. · filed 1995-10-04(a)(2)

Despite the venue statute’s recent revision, Pub .L.Judicial Improvements Act of 1990, No. 101-650, Title III, § 311, which replaced venue based on where the cause of action arose with venue based on substantial acts, venue must still be established as to each defendant.
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Section 1391(b)(2) requires venue to be proper for each defendant in a suit with multiple defendants.

Ia, Inc. v. Thermacell Technologies, Inc. · filed 1997-11-10(b)(2)

As discussed above, this court finds that venue is proper in this district under § 1391(b)(2) with respect to Thermaeell and Pidorenko, but not proper with respect to Monroe.
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Section 1391(e)(1)(C) permits venue in a civil action against federal officers in a district where at least one of multiple plaintiffs resides, if no real property is involved.

F.L.B. v. Lynch · filed 2016-04-15(e)(1)(C)

The Court is satisfied that venue is proper because at least one plaintiff resides in Washington, that the joinder of additional plaintiffs who live outside Washington does not fundamentally change the nature of this litigation, and that, by not earlier challenging venue, defendants waived any argument to the contrary.
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Section 1391(b) requires venue to be established for the action against all defendants; one defendant’s residence alone does not establish venue for the entire action.

Securities and Exchange Commission v. RMR Asset Management Company · filed 2020-05-18(b)

Defendant has not established that this action could have been brought against all defendants in the District of New Jersey. Accordingly, Defendant has failed to establish that this action could have been brought in the District of New Jersey.
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Section 1391(b) requires a basis for venue that covers every defendant.

The Escal Institute of Advanced Technologies, Inc. v. Treadstone 71, LLC · filed 2023-07-27(b)

Because § 1391(b) does not provide a basis for venue over all Defendants in this District, I may exercise my discretion to sua sponte dismiss or, “in the interest of justice,” transfer this action under 28 U.S.C. § 1406(a).
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Section 1391(b)(1) and (2) place venue where the defendant resides or where the conduct giving rise to the claim occurred.

McGary v. Inslee · filed 2023-09-08(b)(1) and (2)

Venue is proper where the defendant resides or where the conduct complained of occurred. 28 U.S.C. § 1391(b)(1) and (2). McGary alleges that he was wronged in New Mexico, by residents of New Mexico. Venue is not proper for McGary’s claims against Roberts and Scholl.
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Section 1391(b)(1) permits venue where the defendant resides, while Section 1391(b)(2) permits venue where the events giving rise to the claim occurred.

Boggs v. The City of New York · filed 2023-09-11(b)(1), (b)(2)

Because he names only the City of New York, venue under Section 1391(b)(1) is proper in this District and the Eastern District of New York. Because the events giving rise to Plaintiff’s claims occurred Kings County, venue is proper under Section 1391(b)(2) only in the Eastern District of New York.
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Section 1391(b)(1)–(2) permits venue where at least one defendant resides if all defendants reside in the same state, or where a substantial part of the relevant events or property is located.

Provino v. Wray · filed 2023-10-10(b)(1)–(2)

There is no indication in Plaintiff’s Complaint that any Defendant resides in the Western District of Texas, that any of the events or omissions occurred here—let alone a substantial part of them—or that the property at issue is located here.
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Section 1391(b) makes venue improper in a district where the defendants do not reside and no substantial part of the events giving rise to the claim occurred.

Roberts v. USA · filed 2023-10-18(b)

The Magistrate Judge determined that Defendants do not reside in South Carolina and that Plaintiff has not alleged that a substantial part of the events giving rise to this action occurred in South Carolina.1 ... Accordingly, upon review of the record, the Report, and the applicable law, the Court agrees with the recommendation of the Magistrate Judge that venue is improper in this district.
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Section 1391(b)(1) and (2) make venue improper in a district where the defendants are located elsewhere and the events giving rise to the claim occurred elsewhere.

Ojo v. WE Pebble Point, LLC · filed 2023-10-24(b)(1), (2)

Because Plaintiff filed this action regarding events occurring in Indianapolis, Indiana, where the defendants are located, 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 based on a defendant’s residence or where a substantial part of the events giving rise to the claim occurred.

Emrit v. Grammy Awards, The · filed 2023-10-26(b)

The Magistrate Judge determined that Defendant does not reside in South Carolina and that Plaintiff has not alleged that a substantial part of the events giving rise to this action occurred in South Carolina. ... Upon such review, the Court agrees with the recommendation of the Magistrate Judge ... that venue is improper in this district.
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Section 1391(b)(1) and (2) do not permit venue in a district where neither the defendant nor the events giving rise to the claim are located.

Samuels v. Brooklyn · filed 2023-11-16(b)(1), (b)(2)

Because Defendant is located in Brooklyn, New York and the alleged events appear to have occurred in Brooklyn, New York, where Defendant is located, 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)(1) and (2) do not establish venue in a district where the defendant does not reside and no substantial part of the events giving rise to the claim occurred.

Hafner v. Menendez · filed 2023-11-21(b)(1), (2)

... occurred in this District, from the face of the complaint, it is clear that venue is not proper in this court under either RICO’s venue provision or Section 1391(b)(1), (2).
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Section 1391 does not permit venue in a district where no defendant resides and none of the events giving rise to the claim occurred when another qualifying district is available.

Proctor, Jr. v. Reifer · filed 2023-12-13(b)

The Report was issued on November 6, 2023, recommending Plaintiff’s case be transferred to the United States District Court for the Western District of Pennsylvania because none of the 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. Therefore, venue under 28 U.S.C. § 1391 is not appropriate in the District of South Carolina. ... Therefore, the Court adopts the Report (DE 5) and incorporates it herein by reference.
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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, with a fallback district if neither basis applies.

Berns v. Clayton County Sheriff's Office · filed 2023-12-20(b)

The Court has reviewed the complaint and concludes it is clear from the face of the complaint that the District of Kansas is not a proper venue for this action. No defendant resides in the District of Kansas, none of the events giving rise to the claims occurred in the District of Kansas, and the events underlying the claims occurred within the Northern District of Iowa.
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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 giving rise to the claim occurred.

McCabe v. Trump · filed 2024-01-02(b)(1), (b)(2)

Thus, Plaintiff does not allege facts sufficient to show that this court is a proper venue for her claims under state law, under Section 1391(b)(1). In addition, because she alleges that the events giving rise to her claims under state law occurred in Grand Rapids, Kent County, Michigan, which lies within the Western District of Michigan, see 28 U.S.C. § 102(b)(1), and in Brooklyn, Kings County, New York, which lies within the Eastern District of New York, see 28 U.S.C. § 112(c), Plaintiff has also not alleged facts sufficient to show that this court is a proper venue for her claims under state law, under Section 1391(b)(2).
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Section 1391(b) permits venue where defendants reside or a substantial part of the events giving rise to the claim occurred.

(PS) Holmes v. Chen · filed 2024-01-04(b)

None of the events in this case relate to the Eastern District of California.
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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 claims occurred, when another district contains both.

Anderson, John v. York · filed 2024-01-10(b)

Based on defendants’ submissions, I agree that this court is not a proper venue for this lawsuit, at least as currently constructed—the events in question took place at WCI, which is in the Eastern District, and the current defendants all reside in the Eastern District. See 28 U.S.C. § 1391(b).
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Section 1391(b) permits venue where a defendant resides under the statute’s conditions or where a substantial part of the events giving rise to the claim occurred.

Jefferson v. Herrera · filed 2024-01-09(b)

In this case, the claim arose in San Luis Obispo County, which is in the Central District of California, and it does not appear any defendant resides within this district. Therefore, plaintiff’s claims should have been filed in the United States District Court for the Central District of California.
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Applicability to judicial branch officials

Section 1391(e) applies to executive branch agencies and cannot supply personal jurisdiction over judicial branch officials.

Duplantier v. United States · filed 1979-06-04(e)

It is therefore reasonable to conclude, and the Court so holds, that the Judicial Ethics Committee, its Chairman, Judge Tamm, and the clerks of court, judicial employees acting in concert with the Committee, are also part of the judicial branch. Accordingly, 28 U.S.C. § 1391(e) can not vest this Court with personal jurisdiction over these parties.
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Section 1391(e) does not extend to officials and committees of the judicial branch.

Duplantier v. United States · filed 1979-12-12(e)

Since Judge Tamm and the Committee remain part of the judicial branch of government, the provisions of 28 U.S.C. § 1391(e) cannot be used to establish personal jurisdiction over them.
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Collusive joinder to establish venue

Venue based on a joined plaintiff is improper if the joinder was solely to create venue, but a bona fide purpose for the transaction defeats that objection.

National Distillers & Chemical Corp. v. Department of Energy · filed 1980-09-30(e)(4)

In its February 26, 1980 memorandum opinion, this Court held that venue in federal court is not proper if it has been obtained by means of a collusive joinder of a party. ... Nevertheless, although the issue is not free from doubt, the Court concludes that the plaintiffs have demonstrated a bona fide purpose for the transfer unrelated to the establishment of venue in this district.
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Section 1391(e)(4) does not permit a plaintiff to establish venue by collusively adding a party.

National Distillers & Chemical Corp. v. Department of Energy · filed 1980-02-26(e)(4)

The Court, therefore, concludes that venue is not properly founded if it has been obtained by means of a collusive addition of a party.
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Venue when defendants reside in one division

Sections 1391(a) and (c), read with the divisional venue statute, require a suit against multiple defendants residing in one division to be brought in that division.

McCroskey v. Texas Marine Survey Co. · filed 1980-08-27(a), (c)

The court is of the opinion that a pragmatic and logical construction of 28 U.S.C. §§ 1393(a) and (b), the division venue statute, read together with 28 U.S.C. §§ 1391(a) and (c) compels the conclusion that a suit brought against multiple defendants residing in a single division must be brought in that division notwithstanding the express language in 28 U.S.C. § 1393(a).
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Section 1391(a) permits a diversity action to be brought in a district where all defendants reside.

Omni Exploration, Inc. v. Graham Engineering Corp. · filed 1983-04-27(a)

In the case sub judice there is no question that the case could have been brought in the Southern District of Texas, as it is the place where all the defendants reside. 28 U.S.C. § 1391(a).
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Section 1391 permits venue in a diversity action in a district where all defendants reside.

Intergraph Corp. v. Stottler, Stagg & Associates, Inc. · filed 1984-10-16(a), (c)

It is clear that Stottler, Stagg would have been amenable to suit there, and venue would, of course, be proper there since all the defendants concededly reside in that district. 28 U.S.C. §§ 1391(a), 1391(c).
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Section 1391(b) makes venue improper in a district where the claim did not arise and some defendants did not reside.

LaVay Corp. v. Dominion Federal Savings & Loan Ass'n · filed 1986-09-25(b)

Even if Dominion transacted business in Maryland, venue was improper under § 1391(b) because the presence of the named individual defendants precluded venue in Maryland.
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Section 1391(b) permits a federal question action in a district where all defendants reside or where the claim arose.

Martin-Trigona v. Meister · filed 1987-03-19(b)

As both defendants, not to mention plaintiff, reside in Connecticut, and given that at least “... a substantial portion of the acts or omissions giving rise to the action[] occurred ...” in Connecticut, venue is placed properly in the District of Connecticut.
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Section 1391(a) permits an action to be brought in a district where all defendants reside.

First City Federal Savings Bank v. Register · filed 1988-01-26(a)

Since all defendants reside in the Southern District of Florida, the action might have been brought there originally. See 28 U.S.C. § 1391(a).
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Subsections (a) and (c) permit venue where the defendants reside and define corporate residence for venue purposes.

Alexander & Alexander, Inc. v. Donald F. Muldoon & Co. · filed 1988-03-30(a), (c)

Miro, which is incorporated in Texas and has its principal place of business in Dallas, is clearly subject to personal jurisdiction in Texas, as is Carlos Miro, who is a citizen of Texas. Venue is also clearly proper as to those defendants, pursuant to 28 U.S.C. §§ 1391(a), (c).
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Section 1391(b) does not permit venue based on a defendant’s residence when the defendants reside in different states; venue may be proper where a substantial part of the claim occurred.

Industri & Skipsbanken A/S v. Levy · filed 1995-06-19(b)

Inasmuch as all defendants do not reside in the same state, the first venue alternative does not apply. However, both the Southern District of New York and the Southern District of Texas are proper venues pursuant to subdivisions (2) and (3) of § 1391(b). Thus, as a matter of venue the case may properly be transferred to the Southern District of Texas.
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Law changed since Public Law 112-63, §§ 202 and 205 (effective January 6, 2012) made the substantial-events ground available regardless of whether all defendants reside in one state.

Under the version of § 1391(a) applied here, when all defendants reside in the same state, venue lies only in a district in that state where a defendant resides; the substantial-events ground applies only when defendants reside in different states.

Dashman v. Peter Letterese and Associates, Inc. · filed 1998-04-02(a)(1)-(2)

Viewed in the proper historical context, § 1391(a), like § 1391(b), provides that in a case in which all defendants reside in the same state, venue lies only in that state, and, specifically, only in a district within that state in which one of the defendants resides. If, and only if, defendants do not all reside in the same state, then, and only then, venue lies in a district in which a substantial part of the events or omissions giving rise to the claim occurred.
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Section 1391 permits venue in the district where the defendants reside.

Pacific Aerospace & Electronics, Inc. v. Taylor · filed 2003-06-20

All defendants reside in or about Wenat-chee, Washington. Therefore, under 28 U.S.C. § 1391, venue is proper where the defendants reside-here in the Eastern District.
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In a diversity case, venue is proper in a district where any defendant resides if all defendants reside in the same state.

Hanover Insurance v. Paint City Contractors, Inc. · filed 2004-01-07(a)(1)

All defendants are residents of Maryland. ... Accordingly, this lawsuit could have been brought originally in the District of Maryland pursuant to 28 U.S.C. § 1391(a)(1) and is eligible for transfer to that district under 28 U.S.C. § 1404(a).
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In a diversity action, venue is proper in a district where a defendant resides if all defendants reside in the same state.

Eui Seob Kim Ex Rel. Cleaners Co. v. Kim · filed 2004-06-29(a)(1)

There is no question that the action could have been filed in the Northern District of Illinois where Defendants reside.
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Section 1391(b) permits venue in a district where a defendant resides when all defendants reside in that state.

Abira Medical Laboratories, LLC v. Alliant Health Plans and Affiliates · filed 2024-05-28(b)

Under 28 U.S.C. §1391(b), venue is proper in “a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located.” ... Thus, venue is proper in the Northern District of Georgia.
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Application to territorial courts

Section 1391’s venue requirements do not apply when the District Court of the Virgin Islands hears a local cause under its territorial jurisdiction.

Godfrey v. International Moving Consultants, Inc. · filed 1980-12-12

In the case at bar, this Court’s exercise of its adjudicatory powers is based on its grant of authority to hear “causes in the Virgin Islands”, 48 U.S.C. § 1612. The venue requirements of 28 U.S.C. § 1391, therefore, are inapplicable.
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Section 1391(a)(1) governs venue in United States district courts and does not apply to the Court of Federal Claims.

Manuel v. United States · filed 2014-03-07(a)(1)

Furthermore, plaintiffs reliance on 28 U.S.C. § 1391 also fails. ... Section 1391 of Title 28 of the United States Code states “[e]xcept as otherwise provided by law — (1) this section shall govern the venue of all civil actions brought in district courts of the United States.”
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Place of performance in contract actions

Section 1391(b)(2) permits venue for a breach of contract claim where a substantial part of the contract’s negotiation, performance, or expected payment occurred.

Thompson Corrugated Systems, Inc. v. Engico S.r.l. · filed 2020-08-12(b)(2)

The Court concludes that the foregoing events occurring, at least in part, in Illinois, are sufficient to amount to “a substantial part of the events or omissions giving rise to” this case. Accordingly, they are sufficient to establish the Southern District of Illinois as an appropriate venue under 28 U.S.C. § 1391(b)(2) for this breach of contract case.
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For a breach of contract claim, venue is proper in the district where the contract was to be performed; when the contract does not specify a place of performance, the delivery site can be that place.

American Carpet Mills, Division of Keller Industries, Inc. v. The Gunny Corporation · filed 1981-07-06(a)

As Gunny admits, in an action for breach of contract, venue is proper at the place of performance. ... Since the contract did not stipulate place of performance and Gunny had breached the contract by failing to deliver the jute to American in Savannah, Savannah was the locus of performance.
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Section 1391(a)(2) permits venue in the district where the contract giving rise to the dispute was made.

Ward v. INVISTA S.A.R.L., LLC · filed 2008-03-10(a)(2)

Defendant meets the first requirement of the statute because this matter could have been brought in the Eastern District. See 28 U.S.C. § 1391(a)(2) (the place of contract with NGD); 28 U.S.C. § 1409(a) (providing venue for proceedings related to the bankruptcy matter).
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Section 1391(f)(1) permits venue for a contract claim against a foreign state in a district where a substantial part of the contract was performed.

Universal Trading & Investment Co. v. Bureau for Representing Ukrainian Interests in International & Foreign Courts · filed 2012-09-19(f)(1)

UTICo’s performance is a significant component of the contract claims and constitutes an event giving rise to the claims.
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Section 1391(b)(2) permits venue where a substantial part of the events or omissions giving rise to a claim occurred, including where a contract payment was due but not made.

Shared Medical Equipment Group, LLC v. Simi Valley Hospital & Healthcare Services · filed 2014-02-25(b)(2)

Under 28 U.S.C. § 1391(b)(2), a civil action may be brought in “a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.” ... Here, as Shared Medical points out, its breach of contract claim arises from Simi Valley’s failure to send an $80,000 payment to Shared Medical in this district. (See Compl. (dkt. # 1) ¶¶ 33^17.) This makes venue in this district proper.
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Section 1391(b)(2) permits venue in a contract dispute where a substantial part of the events giving rise to the claim occurred, including where the contract was largely performed.

CONLIN & CO., LLC v. TAYLOR · filed 2020-02-05(b)(2)

In contract disputes, courts “generally look to the place of performance of a contract in determining whether venue is proper.” Id. Although the eventual sale of Taylor Security may have occurred in Maryland, plaintiff’s claims center on the alleged breach of a contract that was largely performed by plaintiff in Wayne, Pennsylvania. Thus, the Court concludes that venue is proper in this district.
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Section 1391(b)(2) requires a substantial part of the events or omissions giving rise to the claim to occur in the district; filming and marketing there did not establish venue for a claim arising from nonpayment elsewhere.

GETTING GRACE FILM, LLC v. HANNOVER HOUSE, INC. · filed 2020-09-04(b)(2)

Here, we find that the acts or omissions that gave rise to Plaintiff's claims all occurred in Arkansas, not Pennsylvania. While “Getting Grace” was filmed in Pennsylvania, and Pennsylvania audiences may have been targeted through advertisements and marketing, these acts are not what gave rise to this action. This action arises from Defendants’ alleged failure to pay monies owed to Plaintiff pursuant to the Agreement and associated Promissory Notes.
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Section 1391(b)(2) permits venue in a contract dispute where a substantial part of the contemplated performance occurred.

Jacobs v. Sustainability Partners LLC · filed 2020-09-18(b)(2)

However, based on the place of performance of the contract, venue properly lies in this district pursuant to § 1391(b)(2).
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Section 1391(b)(2) permits venue where the contracts at issue were negotiated and signed and one was to be performed.

Zodiac 21, Inc. v. Oyo Hotels, Inc. · filed 2020-11-03(b)(2)

Venue in this Court is proper under 28 U.S.C. § 1391(b)(2) because the Zodiac-Oyo contract was negotiated, signed, and to be performed in this District22 and the Trident-Oyo contract was negotiated and signed in this District.
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Section 1391(b)(2) permits venue in a district where the contracts at issue were negotiated, signed, or to be performed.

Trident Hospitality, Inc. v. Oyo Hotels, Inc. · filed 2020-11-04(b)(2)

Venue in this Court is proper under 28 U.S.C. § 1391(b)(2) because the Zodiac-Oyo contract was negotiated, signed, and to be performed in this District22 and the Trident-Oyo contract was negotiated and signed in this District.
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Section 1391(b)(2) permits venue for a contract claim in the place of intended performance.

Eng v. Banta · filed 2023-06-30(b)(2)

Hawai‘i was/is the place of performance and Miller should have anticipated being sued in Hawai‘i for failing to perform under the Notes. ... Because the Court concludes that jurisdiction and venue are proper in Hawai‘i , the Court DENIES Miller’s alternative motion to dismiss for improper venue and will allow for jurisdictional discovery on that claim.
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Venue after removal

Section 1391’s general venue rules yield to § 1441 in removed actions.

The Blacklands Railroad v. Northeast Texas Rural Rail Transportation District · filed 2019-08-05(a)

The removal statute, 28 U.S.C. § 1441 supersedes § 1391 in removed actions.
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Section 1391’s general venue rules do not apply to cases removed from state court.

Biddle v. Bradshaw · filed 2019-06-17

However, the general venue statute does not apply to cases that have been ... removed from state to federal court.
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Section 1391 does not govern venue in cases removed from state court.

Micro-Surface Finishing Products, Inc. v. SDI, Inc. · filed 2015-05-01

As SDI accurately points out, venue of removed cases is governed by 28 U.S.C. § 1441(a), and the general venue statute, 28 U.S.C. § 1391, has no application.
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Section 1391(f) applies to actions against foreign states originally filed in federal court, but does not make venue improper in the federal court that receives a removed action.

Translinear, Inc. v. Republic of Haiti · filed 1982-04-07(f)

However, 28 U.S.C. § 1391(f) applies only to actions which originally are “brought” in federal court. In that the present case was initially brought in state court and removed to federal court, section 1391(f) does not serve to render venue improper in the Southern District of Texas.
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Section 1391(a) does not govern venue in diversity cases removed from state court.

Dunn v. Textron · filed 1995-12-19(a)

Defendants’ reliance on § 1391(a) is misplaced, as it does not govern venue in diversity eases removed from state court.
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Section 1391 does not govern venue in cases removed from state court; the removal statute does.

Pt United Can Company Ltd. v. Crown Cork & Seal Company, Inc., F/k/a Continental Can Company Richard Krzyzanowski John W · filed 1998-02-25

Moreover, the removal statute, and not the ordinary federal venue statute, 28 U.S.C.A. § 1391 (West Supp.1997), governs venue in removed eases.
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Section 1391 does not govern venue in an action removed from state court.

Kumarelas v. Kumarelas · filed 1998-09-04

Because venue is proper under section 1441(a), defendant may not challenge venue under section 1391 even though venue may not have been proper if the case had been brought initially in this district.
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Section 1391 does not govern venue in cases removed from state court; Section 1441 governs venue after removal.

IBC Aviation Services, Inc. v. Compañia Mexicana De Aviacion · filed 2000-12-19

Venue in cases removed from state court are governed by 28 U.S.C. § 1441, rather than 28 U.S.C. § 1391, which is the general venue statute.
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Section 1391 does not govern venue in the district where an action is removed from state court; the removal statute governs that venue.

Allied Van Lines, Inc. v. Aaron Transfer & Storage, Inc. · filed 2002-05-14

Venue in an action removed from state court to federal court is governed by the removal statute, 28 U.S.C. § 1441, not by the general venue statute, 28 U.S.C. § 1391.
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Section 1391(a) does not govern venue in an action removed from state court.

Lynch v. Vanderhoef Builders · filed 2002-09-19(a)

There is no question that this Court embraces the Circuit Court of Cecil County, Maryland, and therefore, venue is proper pursuant to 28 U.S.C. § 1441(a), and transfer through 28 U.S.C. § 1391(a) does not apply.
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Section 1391 does not govern venue in a case removed from state court.

Bank Express International v. Kang · filed 2003-01-15

However, § 1391 does not apply to this case because it was removed from state court.
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Section 1391(b) does not govern venue in a case removed from state court; § 1441(a) controls removal venue.

Lundahl v. Public Storage Management, Inc. · filed 2003-03-18(b)

While preparing to oppose plaintiff’s brief for purposes of this appeal, Lilly for the first time realized that removal venue is controlled by 28 U.S.C. § 1441(a) which provides that cases may be removed to “the district court of the United States for the district and division embracing the place where such action is pending.” Thus, the dismissal based on § 1391(b) was improvidently granted, and venue in the federal district court for the district of Utah is proper.
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Section 1391 does not determine venue for an action removed from state court; section 1441(a) governs.

Ferrell v. Grange Insurance · filed 2005-02-03

Defendant Motorist has also moved to dismiss under Fed. R. Civ. Pro. 12(b)(3), arguing that venue is improper under 28 U.S.C. § 1391 because both defendants are incorporated in Ohio, a substantial part of the events giving rise to the claim took place in Ohio, and both defendants are subject to jurisdiction in the Southern District of Ohio. However, Defendant is relying upon the wrong statute to determine venue.
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Section 1391 does not govern venue in a case removed from state court; the removal statute governs instead.

Jenkins v. Albuquerque Lonestar Freightliner, LLC · filed 2006-12-01

When an action is removed to federal court, the removal statute (28 U.S.C. § 1441), rather than general venue statute (28 U.S.C. § 1391), governs the issue of venue.
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Section 1391 does not govern venue after removal; § 1441(a) establishes venue in the district where the state action was pending.

Keston v. FirstCollect, Inc. · filed 2007-10-31

Defendants also challenge this action on the basis of improper venue, citing 28 U.S.C. § 1391. The proper venue statute in a removal action is 28 U.S.C. § 1441(a). ... I, therefore, find that venue is proper in this case.
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Section 1391 does not govern venue after removal from state court, so a removing defendant cannot seek dismissal on § 1391 grounds.

Scholl v. Sagon RV Supercenter, LLC · filed 2008-02-27

Gulf Stream removed the action to this Court under 28 U.S.C. § 1441(a). As a result, it is precluded from moving for dismissal on § 1391 grounds.
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Section 1391(a) governs venue in actions initially filed in federal court, but not actions removed from state court.

Reassure America Life Insurance v. Midwest Resources, Ltd. · filed 2010-06-14(a)

The Supreme Court has noted, however, that § 1391 applies only to actions initially brought in federal court, not to actions such as this one that are initially filed in state court and subsequently removed to federal court.
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Section 1391 does not govern venue in a removed action when a defendant named in the state court complaint is served after removal.

Smith v. JP Morgan Chase Bank, N.A. · filed 2010-08-03

The question for the court is whether the general removal statute, 28 U.S.C. § 1441(a), dictates venue, or whether the general venue statute, 28 U.S.C. § 1391, applies. As explained below, I hold that controlling precedent and statutory text dictate that in a circumstance such as this venue is governed by the removal statute.
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Section 1391 generally governs venue, but it does not govern venue in removed cases.

Docrx, Inc. v. Dox Consulting, LLC · filed 2010-09-07

While the propriety of venue normally is governed by 28 U.S.C. § 1391, the general venue statute, it is clear that “[v]enue in removed cases is governed solely by § 1441(a).”
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Section 1391’s general venue rules do not govern cases removed from state court; venue for those cases is governed by § 1441(a).

McPhearson v. Anderson · filed 2012-07-06

However, “venue for actions brought in state court and later removed to federal court is governed by 28 U.S.C. § 1441(a), and not the general venue rules found in 28 U.S.C. § 1391.” ... Any objection to venue is unfounded.
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Section 1391 does not govern venue in an action removed from state court.

Executive Wings, Inc. v. Dolby · filed 2015-09-16

But § 1391 does not apply in every case. ... EWI filed this action in the Court of Common Pleas of Allegheny County, Pennsylvania, ECF No. 1, at ¶ 1, which is located in the Western District of Pennsylvania, and the Defendants removed it here. Venue is proper in this district by virtue of § 1441(a).
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Section 1391(a)(1) applies to actions brought in federal district court and does not govern venue in removed actions.

Murcia v. a Capital Electric Contractors, Inc. · filed 2017-09-05(a)(1)

That provision applies to “civil actions brought in district courts of the United States.” 28 U.S.C. § 1391(a)(1). But this action was not brought in federal court; rather, it was brought in D.C. Superior Court and removed here by Defendants. “[B]ecause this is a removed action,” § 1391 “has no application to this case.” Polizzi v. Cowles Magazines, Inc., 345 U.S. 663, 665 (1953).
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Section 1391 governs venue in actions originally filed in federal court, but does not apply to removed actions.

Rust Consulting, Inc. v. Schneider Wallace Cottrell Konecky Wotkyns LLP · filed 2018-03-09

But it is well established that § 1391 does not apply to removed actions - it only applies to actions originally filed in federal court.
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Section 1391(b) does not govern venue in a removed case; § 1441(a) does.

Morrison Constr. Co. v. Blurock Concrete, LLC · filed 2019-03-29(b)

However, removal venue is controlled not by § 1391(b), but by 28 U.S.C. § 1441(a), which provides that cases may be removed to "the district court of the United States for the district and division embracing the place where such action is pending."
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Section 1391 does not govern venue in cases removed from state court to federal court.

Gabriel Farms Inc v. G&M Farms Inc · filed 2020-02-20

As Plaintiff notes, Resp. [ECF 14] at 12, § 1391 has “no application” to removed cases.
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Section 1391 governs venue in actions initially brought in federal court, but does not govern venue in removed actions.

MINTER v. ACME MARKETS, INC. · filed 2020-03-25

However, as the Supreme Court stated in Polizzi v. Cowles Magazines, Inc., 345 U.S. 663 (1953), § 1391 only applies to actions initially brought in federal court, not to actions—such as this one—which were originally filed in state court and subsequently removed to federal court.
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Section 1391 does not govern venue in an action removed from state court; Section 1441(a) governs instead.

McGowan v. Camp Agawak, LTD · filed 2020-10-01(a)

However, venue in a case removed from state court is governed not by Section 1391 but by a different statutory provision, 28 U.S.C. § 1441(a).
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Section 1391 does not govern the initial venue of a removed action; Section 1441(a) does.

Nkumba v. GM Financial · filed 2020-12-29

Indeed, the general venue statute, 28 U.S.C. § 1391 “has no application to a removed action. Venue of removed actions is governed by 28 U.S.C. § 1441(a).”
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Section 1391(b) does not govern venue in an action removed from state court.

Rhythm Engineering, LLC v. A.D. Electric, Inc. · filed 2021-05-07(b)

This case, however, was not originally filed in this court but was removed from state court. Therefore, § 1391 is not applicable.
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Section 1391 does not govern venue in a removed action; § 1441(a) does.

Altschuler v. Chubb National Insurance Company · filed 2021-09-20

Because this is a removal case, however, venue is governed by 28 U.S.C. § 1441(a).
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Section 1391(b) does not govern venue in an action removed from state court; § 1441(a) does.

Estate of Chad Logan v. Busch · filed 2021-12-06(b)

As a removal action, 28 U.S.C. § 1441(a) establishes the proper venue, not § 1391(b).
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Section 1391 does not determine venue for an action removed from state court.

Nelson v. Foundation Partners Group, LLC · filed 2022-05-25

Second, the general federal venue statute does not apply because this matter was removed from state court.
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Section 1391 does not govern venue in an action removed from state court.

Connell Limited Partnership v. Associated Indemnity Corporation · filed 2023-01-06

However, “§ 1391 has no application to this case because it is a removed action.”
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Section 1391's general venue rules do not govern an action removed from state court; Section 1441(a) governs venue instead.

River Healthcare Inc. v. Baylor Miraca Genetics Laboratories, LLC · filed 2023-03-16

Although Section 1391 generally governs venue, when an action is removed from state court, Section 1441(a) governs the venue inquiry.
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Section 1391 does not govern venue in an action removed from state court.

Stampley v. RCNI Freight LLC · filed 2023-08-18

“[Section] 1391 has no application to a removed action.” ... Instead, venue in removed cases is governed by 28 U.S.C. § 1441(a).
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Section 1391 does not govern venue in an action removed from state court to federal court.

CHESAPEAKE THERMITE WELDING, LLC v. RAILROAD SOLUTIONS, INC. · filed 2024-01-31

In an action removed from state to federal court, § 1391 is not the applicable venue provision.
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Section 1391(b) does not govern venue in cases removed from state court.

Powerhouse Communications, LLC v. Midstate Communication Contractors, Inc. · filed 2024-09-20(b)

Defendants also seek to dismiss this action for improper venue pursuant to Federal Rule of Civil Procedure 12(b)(3), arguing that venue is improper under 28 U.S.C. § 1391(b). Defendants’ argument is unavailing, because that statue does not govern cases removed from state court.
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Section 1391 does not govern venue in a removed action; the removal statute does.

Haag v. Minnesota Logistic, LLC · filed 2025-03-19

Plaintiffs are correct that the venue in this case is governed by the federal removal statute, § 1441, not the general venue statute, § 1391.
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Section 1391 does not govern venue in an action originally filed in state court and then removed to federal court.

SEIDMAN v. HAMILTON BEACH BRANDS, INC. · filed 2025-03-21(a)(1)

Section 1391 has no direct application to actions originally filed in state court and then subsequently removed to federal court.
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Section 1391’s general venue requirements do not apply to cases removed from state court.

Adams v. Zurich American Insurance Company · filed 2025-08-05

Zurich’s argument that Adams has not met “the requirements” of § 1391 is therefore inapplicable in this removed case.
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Section 1391 does not govern venue in cases removed from state court; the removal statute governs instead.

Freeman · filed 2025-12-29

Venue for removed cases, however, is governed by the removal statute, 28 U.S.C. § 1441, not by 28 U.S.C. § 1391.
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Section 1391 governs venue in federal civil actions but provides no basis for a motion to change venue after the action has been dismissed.

Villard · filed 2026-04-09

Plaintiff cites 28 U.S.C. § 1391 in support of his motion. ... None of this law, though, foresees a motion for a change of venue as being a proper procedural step or requiring adjudication by a court once the civil action has been dismissed.
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Pendent venue

Section 1391(b) does not allow an unrelated claim arising outside the district to proceed there through pendent venue merely because an earlier suit is pending there.

Seamon v. Upham · filed 1983-02-14(b)

For all the above reasons, it is concluded that venue is improper for this claim, which arises outside the Eastern District of Texas.
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Law changed since Pub. L. 112-63 (effective Jan. 6, 2012) eliminated the separate general venue rules for diversity and federal-question claims.

Section 1391(b) permits venue for related claims when another statute establishes proper venue.

Witt v. Merrill Lynch, Pierce, Fenner & Smith, Inc. · filed 1985-02-06(b)

We find, based upon the facts alleged, that the claim arose in this district. However, even if that determination is in error,, the final phrase of § 1391(b) must not be disregarded. “[Ejxcept as otherwise provided by law” ensures that proper venue established under other statutory authority will be proper also for other related violations alleged.
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Section 1391(b) governs venue when a plaintiff adds a federal-question claim to a diversity action; venue for the added claim must be proper where the defendants reside or the claim arose.

Carl A. Bredberg and Diane Bredberg v. Dean Long, Nelda Long, and Realife, Inc., D/B/A Realife Ranch · filed 1985-12-09(b)

But where, as here, the plaintiff asserts a claim against the defendant that provides a non-diversity basis for jurisdiction, § 1391(b) applies and venue is proper only in the district where the defendants reside or in which the claim arose.
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Section 1391(b) ordinarily places venue for § 1981 and § 1983 claims where all defendants reside or the claim arose, but a court may hear related claims through pendent venue when a Title VII claim is properly venued there.

Rodriguez v. Chandler · filed 1986-08-11(b)

On the other hand, plaintiff’s claims under § 1983 and § 1981 would ordinarily have to be brought in the northern district — “where all the defendants reside or in which the claim arose,” pursuant to 28 U.S.C. § 1391(b). Yet given the propriety of venue over the Title VII claims, this Court may also exercise venue over plaintiff's factually related claims under § 1981 and § 1983. ... Defendants’ motion to dismiss for improper venue is thus denied.
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Claims governed by § 1391(b) may proceed under pendent venue when they share operative facts with a principal claim for which venue is proper under a special statute.

Wichita Federal Savings & Loan Ass'n v. Landmark Group, Inc. · filed 1987-11-24(b)

Venue for the Commodities Exchange Act claim, as well as the pendent state claims, must be grounded upon § 1391(b). ... The court thus concludes that the claims arise out of the same set of operative facts, and that the securities fraud claim is here the “principal” claim. Therefore, because venue is properly laid in this district as to the Securities Act claim, this court also finds venue proper in this district as to the remaining claims.
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Section 1391(a)(2) requires venue to be established for each claim against each defendant; one defendant’s conduct does not establish venue for another.

McCaskey v. Continental Airlines, Inc. · filed 2001-03-09(a)(2)

Simply put, there is no pendant venue under 28 U.S.C. § 1391(a)(2).
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Section 1391(b)(2) does not govern a related claim when a limiting special venue statute provides venue for the cause of action.

Pacer Global Logistics, Inc. v. National Passenger RR Corp. · filed 2003-07-10(b)(2)

The general venue statute, § 1391(b)(2), which previously appeared to provide venue of Pacer’s state law claim against Jimco in California, does not, in fact, govern. This is so because venue has been “otherwise provided by law.”
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Section 1391(b)(2) permits venue for related nonpatent claims where a substantial part of the events or omissions giving rise to them occurred.

Norkol/Fibercore, Inc. v. Gubb · filed 2003-08-25(b)(2)

Rather, venue of these claims is governed by § 1391(b)(2), the section of the general venue statute that applies to cases where jurisdiction is not founded solely on diversity of citizenship. Section 1391(b)(2) states that venue exists in a district where “a substantial part of the events or omissions giving rise to the claim occurred.” Gubb does not dispute that this requirement is satisfied in the present case.
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Section 1391(b) permits related claims to be heard together under pendent venue when one claim is properly venued, the claims share a common nucleus of operative facts, and hearing them together serves judicial economy.

CSX TRANSPORTATION, INC. v. ZAYO GROUP LLC · filed 2022-06-03(b)

Courts within this Circuit have recognized that "a claim that is not properly venued standing alone still can be heard by a court as long as another properly venued claim arising out of a common nucleus of operative facts also is brought at the same time in the same district" and the interests of judicial economy would be furthered by hearing the claims together. ... Accordingly, the Court finds that the interests of judicial economy would be furthered by hearing CSX Transportation's claims together. Therefore, the Court ADOPTS the portions of the Report and Recommendation to the extent that it concludes that venue is proper in this Court, and Zayo Group's Motion to Dismiss as it relates to venue is DENIED.
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Section 1391(b) permits a court to hear closely related claims under pendent venue even when those claims do not independently meet its venue requirements.

Unique v. Claybaugh · filed 2024-01-17(b)

Because Counts III and IV are closely related both factually and legally to Counts I and II, they can be pursued in this Court under the doctrine of pendent venue notwithstanding the fact that they do not meet the statutory venue requirements under 28 U.S.C. § 1391(b).
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Venue for municipal corporations

Section 1391(c) permits a municipal corporation to be sued in the district where it does business.

Kahhan v. City of Fort Lauderdale · filed 1983-06-24(c)

The City of Fort Lauderdale, a municipal corporation doing business as Fort Lauderdale in Southern Florida, may be sued in the Southern District of Florida under this provision as well.
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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 a corporation to be sued in a district where it is doing business.

Furmanite America, Inc. v. Durango Associates, Inc. · filed 1986-09-12(c)

Finally, the Court finds that the action should not be dismissed for improper venue. Fed.R.Civ.P. 12(b)(3). A corporation may be sued in any district where it is “doing business.” 28 U.S.C. § 1391(c). For the reasons discussed above, the defendants’ business contacts in Virginia are ... deemed extensive enough to constitute “doing business” in the state.
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Section 1391(b) and (c) make venue proper in a judicial district where a corporate defendant does business.

Stewart Organization, Inc. v. Ricoh Corp. · filed 1987-02-23(b) & (c)

Because Ricoh does business in the relevant judicial district in Alabama as well as New York, the Northern District of Alabama constituted a proper venue.
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Section 1391(c) permits venue where a defendant corporation was doing business during the acts at issue.

Pickering v. USX Corp. · filed 1992-11-03(c)

Because defendant, a Delaware corporation, was doing business in the State of Utah during the time of the acts complained of in this lawsuit, venue is proper under 28 U.S.C. § 1391(c) (1990 & Supp.1992).
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Section 1391(c) makes venue proper for a corporation wherever it is subject to personal jurisdiction when the action begins.

Wilson v. DIRECTBUY, INC. · filed 2011-10-27(c)

All three defendant corporations are headquartered in the Northern District of Indiana and are subject to general personal jurisdiction there. Venue would thus also be proper in the Northern District of Indiana. ... 28 U.S.C. § 1391(c) (making venue proper for corporations wherever the corporation is subject to personal jurisdiction when the action is commenced).
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Law changed since Pub. L. 100-702 (1989) replaced the corporate doing-business residence test with a personal-jurisdiction test.

Section 1391 permits venue in a district where a corporate defendant does business.

Cooper v. Valley Line Co. · filed 1970-12-17(c)

Defendant is not registered to do business in the State of West Virginia. However, defendant’s Affidavit states that, at all relevant times, defendant, in fact, was doing business there. Also, the alleged accident occurred at Lock 13 on the Ohio River, which is located at McMehen, West Virginia. Accordingly, defendant would have been amenable to personal service, under Section 31-1-71 of the West Virginia Code, and venue would have existed, under 28 U.S.C. § 1391, in the Southern District of West Virginia.
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Venue after a defendant is added

Venue under § 1391(a) is determined when the action begins and remains proper when a defendant residing in that district is later added.

Louwers v. Knight-Ridder Newspapers, Inc. · filed 1983-09-06(a)

Venue was proper when this case began, the action having been brought in the district of plaintiffs residence. The added defendant resides in this district and can have no cause for contending that venue is improper. Therefore, this court is not deprived of venue in this case.
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Section 1391(a) permits venue in a diversity case where all remaining defendants reside, based on the circumstances when venue is assessed.

Knowlton v. Allied Van Lines, Inc., and Schick Movers, Inc. · filed 1990-04-05(a)

Because Schick has dropped out as a co-defendant, the District of Minnesota is now a district in which all defendants (that is, Allied) reside. Venue is proper there in a diversity case. 28 U.S.C. § 1391(a). It is proper to assess the propriety of venue on the basis of circumstances as they now exist, as opposed to the state of affairs that obtained when the complaint was first filed against two defendants.
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Section 1391(b) permits a suit to be filed where the defendant company is headquartered.

In Re Archer Directional Drilling Services, L.L.C. · filed 2016-01-13(b)

Stanley could have filed his lawsuit in the Houston Division, as Archer’s headquarters are located there. 28 U.S.C. § 1391(b).
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Section 1391(b) makes venue improper in a district when the remaining defendants and the events underlying the claims are located in another district.

COUCH v. ITF · filed 2019-08-20(b)

If the GDC is dismissed, venue would no longer be proper in this district: Plaintiff’s remaining claims involve events occurring in the Southern District of Georgia, and all remaining named parties appear to be located there.
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Section 1391(b) makes venue improper in a district when, after a defendant is dismissed, the remaining defendant resides and the alleged events occurred in another district.

PRESTON v. HALL · filed 2020-04-27(b)

If the Georgia Department of Corrections is dismissed, venue would no longer be proper in this district. Plaintiff’s remaining claims involve events that allegedly occurred at Jenkins Correctional Center-CCA, which is located in the Southern District of Georgia, and the only remaining Defendant, Warden Helton Hall, resides in the Southern District of Georgia as well. ECF No. 1 at 3-4; See 28 U.S.C. § 1391(b).
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Section 1391(b) permits venue in a district where the defendant is based.

Turner v. Trans-India Products, Inc. · filed 2020-07-30(b)

Venue in the Northern District of California would be proper because Defendant is based in Northern California. See 28 U.S.C. § 1391(b).
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Section 1391(b) governs which federal district is a proper venue for a civil action.

Decastro v. Bank OZK · filed 2022-09-06(b)

Because the Court grants Bank OZK’s motion to interplead funds and for dismissal, the Court concludes venue is no longer appropriate in the Eastern District of Arkansas but properly lies in the United States District Court for the Western District of Arkansas.
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Notes 2551–2700 of 8,639, oldest cases first.

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