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No reviewed case has held this section invalid, preempted, superseded or repealed.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

Alternative grounds for venue

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

(PC) Romo v. Los Angeles Sheriff Department · filed 2019-10-30(b)

In this case, the defendants are located in and the claim arose in Los Angeles County, which lies within the jurisdiction of the United States District Court for the Central District of California. Therefore, plaintiff’s claim should have been filed in the Central District.
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A plaintiff’s residence alone does not establish venue under § 1391(b) when the defendants reside elsewhere and the events giving rise to the claim occurred in another district.

Johnson v. Victoria Fire and Casualty Company · filed 2019-11-01(b)

It does not appear that venue is proper here.
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Section 1391(b) permits venue where the defendants reside or a substantial part of the events giving rise to the claim occurred.

(PC) Rogers v. Bilderback · filed 2019-11-04(b)

In this case, the defendants are located, and the claim arose in Los Angeles County, which is in the Central District of California. Therefore, plaintiff’s claim should have been filed in the United States District Court for the Western Division of the Central District of California.
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Section 1391(b) permits venue where a qualifying defendant resides or where a substantial part of the events giving rise to the claim occurred.

Favor VEXATIOUS LITIGANT v. Gray · filed 2019-11-05(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 reside in the same state, (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) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought. 28 U.S.C. § 1391(b). In this case, there is no indication that any of the defendants reside in the Eastern District of California, and the Complaint states that the claim arose in Men’s Central Jail/Los Angeles, as well as a branch location of the Los Angeles Police Department, both of which are in the Central District of California.
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Section 1391 permits venue in a district where the claims arose and the parties are located.

USA ex rel Michael S. Lord v. North American Partners In Anesthesia, LLP · filed 2019-11-07(b)

Venue is appropriate in this court since the claims arose in this district and all parties are located here. See 28 U.S.C. §1391.
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Section 1391(b) permits venue where the defendants reside or a substantial part of the events giving rise to the claim occurred.

(PC) Jones v. Cortez · filed 2019-11-08(b)

28 U.S.C. § 1391(b). In this case, none of the defendants reside in this district. The claim arose ... in Imperial County, which is in the Southern District of California. Therefore, plaintiffs claim should have been filed in the United States District Court for the Southern District of California.
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Section 1391(b) governs where venue is proper based on the alleged facts and named defendants.

Rhoades v. Moore · filed 2019-11-12(b)

However, from the facts alleged and the defendants named, it appears that venue properly lies in the Western District of Tennessee. See 28 U.S.C. §1391(b).
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Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claims occurred.

Flatt v. Aspen Dental Management, Inc. · filed 2019-11-15(b)(2)

The Court finds merit in Aspen’s showing of jurisdiction and venue for the proposed transferee court. (ECF No. 13, PAGEID # 79–80; 28 U.S.C. § 1391(b)(2).) Significantly, Flatt acknowledges that he could have filed his claims in the Western District of Kentucky.
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Section 1391(b) permits venue in a district where the defendants reside or a substantial part of the events giving rise to the claim occurred.

Mousa v. Criminal Intelligence Bureau · filed 2019-11-18(b)

Therefore, Plaintiff’s suit should have been filed in the United States District Court for the Central District of California, Western Division.
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Section 1391(b) permits venue where the defendants reside or a substantial part of the events giving rise to the claim occurred.

(PC) Price v. Espinoza · filed 2019-11-18(b)

In this case, the defendants are located, and the claim arose, in San Bernardino County, which is in the Central District of California. Therefore, plaintiff’s complaint 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 where a defendant resides if all defendants reside in the forum state, or where a substantial part of the events giving rise to the claim occurred.

Godoy v. Brown · filed 2019-11-26(e)

Pursuant to 28 U.S.C. § 1391(e), an action may be brought in either (1) the judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located; or (2) the judicial district in which a substantial part of the events or omissions giving rise to the claim occurred. Accordingly, as explained in the Court’s prior order of dismissal with leave to amend, claims arising out of events occurring at CIM or Lancaster State Prison must be filed in the United States District Court for the Central District of California where CIM and Lancaster State Prison are located, and claims arising out of events occurring at MCSP or SATF” must be filed in the United States District Court for the Eastern District of California where MCSP and SATF are located.
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Section 1391(b) makes venue improper in a district where no defendant resides and no substantial part of the events giving rise to the claim occurred, when another proper district is available.

Panchitkaew v. Blue Ridge Beverage Company, Inc. · filed 2019-11-26(b)

Because Plaintiff does not allege that either Defendant resides in this district or that the events or omissions giving rise to his claims arose in this district, under § 1391(b), venue is not proper here.
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Section 1391(b) permits venue where defendants reside and the claims arise from events in the district.

Richard v. Watkins · filed 2019-12-03(b)

Venue is proper under 28 U.S.C. § 1391(b) because defendants reside in this district and plaintiff’s claims arise from events that occurred in this district.
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Section 1391(b) permits venue in a district where the defendants reside or where a substantial part of the events giving rise to the claim occurred.

Cunningham v. Professional Wiregrass Communications Inc · filed 2019-12-05(b)

As PWC points out, the Northern District of Alabama does not appear to be a proper venue, as none of the defendants reside here and there are no allegations that even a small part of the events or omissions giving rise to the claim occurred here.
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Section 1391(b)(1)-(2) governs proper venue based on a defendant's residence or where a substantial part of the events occurred.

Cole v. Nevada County Jail · filed 2019-12-09(b)(1)-(2)

Venue is proper in the Western District of Arkansas; and the interests of justice would best be served by transferring this case there. 28 U.S.C. § 1391(b)(1)-(2); 28 U.S.C. § 1406(a).
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Section 1391(b)(1)-(2) identifies where venue is proper for a civil action.

Hutcheson v. Nevada County Jail · filed 2019-12-09(b)(1)-(2)

Venue is proper in the Western District of Arkansas; and the interests of justice would best be served by transferring this case there. 28 U.S.C. § 1391(b)(1)-(2); 28 U.S.C. § 1406(a).
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Section 1391(b)(1)-(2) governs where venue is proper for a civil action.

Joyce v. Nevada County Jail · filed 2019-12-09(b)(1)-(2)

Venue is proper in the Western District of Arkansas; and the interests of justice would best be served by transferring this case there. 28 U.S.C. § 1391(b)(1)-(2); 28 U.S.C. § 1406(a).
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Section 1391(b) permits venue where the defendant resides or a substantial part of the events giving rise to the claim occurred.

Maiola v. Greater Baltimore Medical Center · filed 2019-12-09(b)

Venue thus is not in the Northern District of California and instead is in the District of Maryland.
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Section 1391 permits venue in a district where the events giving rise to the claim occurred.

Simonson v. Borough of Taylor · filed 2019-12-10

Venue is appropriate in this court since the alleged constitutional violations occurred in this district and all parties are located here. See 28 U.S.C. §1391.
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Section 1391(b) did not make Oregon a proper venue where no defendant was alleged to reside there and no event giving rise to the claims was alleged to have occurred there.

Wallace v. Longano · filed 2019-12-16(b)

There are no allegations that any of the named defendants reside in Oregon or that any of the events giving rise to plaintiff’s claims occurred in Oregon. See Dkt. 19. Therefore, the District of Oregon is not an appropriate venue. See 28 U.S.C. § 1391(b).
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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.

(PC) McCoy v. Kelso · filed 2019-12-18(b)

Venue is appropriate in the United States District Court for the Eastern District of California, Fresno Division, in this case. Plaintiff asserts claims regarding events that occurred at the California Substance Abuse Treatment Facility in Corcoran, California, against Defendants who are allegedly employed at that institution and reside in this district.
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Section 1391 permits venue where the defendant resides or a substantial part of the events giving rise to the claim occurred.

Hassett v. Beam Suntory · filed 2019-12-18(b)(1), (b)(2)

Here, venue would be proper in the Northern District of Illinois because Defendant's headquarters are located in Chicago, and to a large extent, the events giving rise to Plaintiff’s claims occurred there.
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Section 1391(b) permits venue based on the defendants’ residence or where the events underlying the claims occurred.

American Southern Insurance Company v. Creative Scapes LLC · filed 2019-12-19(b)

Venue is proper in the Northeastern Division of the Northern District of Alabama because the Defendants maintain their principal place of business and residence in Madison County, Alabama, and the facts ... underlying the claims asserted in the complaint occurred in this judicial district. See 28 U.S.C. § 1391(b).
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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.

The Cincinnati Insurance Company v. Norfolk Truck Center, Inc. · filed 2019-12-20(b)

This Court is the appropriate venue for this matter, because Defendant maintains its principal place of business in this District and Division, the fact a substantial part of the events giving rise to the instant claim occurred in this District and Division, and by consent and/or waiver of Defendant.
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Section 1391(b) makes venue improper in a district where no defendant is alleged to reside and no substantial part of the events giving rise to the claim occurred.

Hill v. Abrams · filed 2019-12-20(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 governs whether venue is proper in a federal district court.

FERENCIN v. LEHIGH UNIVERSITY · filed 2019-12-27(a)(1), (2)

Venue is proper in this court under 28 U.S.C. § 1391(a)(1), (2).
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Section 1391(b) does not permit venue for claims in a district where the alleged conduct did not occur and no individual defendant is located.

Poulson v. United States · filed 2019-12-31(b)

When jurisdiction is not based solely on diversity, venue is proper in (1) the district in which any defendant resides, if all of the defendants reside in the same state; (2) the 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) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought. See 28 U.S.C. § 1391(b). ... Here, it is clear from Plaintiff’s Proposed Complaint his § 1983 claims arise out of actions committed at FCI Sheridan. ... Further, Plaintiff has named the United States of America as the sole Defendant and has not named any individual Defendants who are located in the Western District of Washington. Therefore, the Court concludes venue is improper for Plaintiff’s § 1983 claims raised in the Proposed Complaint.
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Section 1391(b) does not make venue proper in the District of Columbia for claims arising in an out-of-state prison when the claims have no connection to the federal defendants named in the suit.

Rindahl v. Robertson · filed 2020-01-03(b)

To the extent that plaintiff alleges constitutional violations against the SDDC, venue here is improper. ... Here, no connection is established between the alleged constitutional violations within plaintiff's state prison and the federal defendants. Therefore, these claims shall be dismissed pursuant to 28 U.S.C. § 1406(a).
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Section 1391(b) sets the districts where a civil action may be filed based on a defendant’s residence, the events giving rise to the claim, or its fallback rule.

(HC) Sanders v. Marshall · filed 2020-01-06(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 Riverside 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) permits a plaintiff to file where the defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred.

Johnson Health Tech North America, Inc. v. Grow Fitness Group, Inc. · filed 2020-01-07(b)

That provision does not require that the defendant reside in the judicial district where the civil action was brought and that a substantial part of the events occurred in that same judicial district. Instead, the requirement is disjunctive: a plaintiff can file a lawsuit in a judicial district either where the defendant resides or where a substantial part of the events or omissions giving rise to the claim occurred.
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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.

Shabazz v. Annucci · filed 2020-01-09(b)

Malone, New York is located in Franklin County, which falls within the Northern District of New York. See 28 U.S.C. § 112(a). Venue is therefore proper in the Northern District of New York. See 28 U.S.C. § 1391(b).
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Section 1391(b) permits venue where defendants reside or where the events giving rise to the claim occurred.

Cunningham v. Jeanpierre · filed 2020-01-10(b)

Venue is proper where defendants to a lawsuit reside or where the events giving rise to the claim took place. 28 U.S.C. § 1391(b).
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Section 1391(b) does not permit venue for § 1983 claims in a district where the defendants do not all reside in the state, the substantial events occurred elsewhere, and the fallback venue provision does not apply.

Phillips v. Austin Police Department · filed 2020-01-10(b)

Subsection two does not apply because a substantial part of the events or omissions giving rise to her claims against the Texas defendants occurred in Texas.
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Section 1391(b) permits venue where the defendant resides or a substantial part of the events giving rise to the claim occurred; a filing bar in that district does not make venue proper elsewhere.

Straw v. State of Indiana · filed 2020-01-14(b)

Notwithstanding the Seventh Circuit’s Order, venue is not appropriate in this Court, but is appropriate in Indiana.
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Section 1391(b)(1) and (2) allow venue in a district 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.

Figueroa v. Koenisgsmann · filed 2020-01-14(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) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.

Holliday v. Murphy · filed 2020-01-16(b)(1), (2)

Because Plaintiff does not allege any facts showing that the defendant resides in this judicial district or that any of the alleged events or omissions giving rise to Plaintiff's claims occurred in this judicial district, venue is not proper in this Court under § 1391(b)(1) or (2).
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Section 1391 permits venue where defendants reside and a substantial part of the events giving rise to the claims occurred.

Social Bicycles LLC v. City of Chicago Department of Transportation · filed 2020-01-22

Venue is proper in this district under 28 U.S.C. § 1391 because defendants are located and reside here and a substantial part of the events giving rise to the claims occurred here.
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Section 1391(b) permits venue in the District of Columbia when the defendants are the District, its transportation agency, and agency employees, and the plaintiff works there.

Battle v. District of Columbia Department of Transportation · filed 2020-01-29(b)

Venue is appropriate in this district under 28 U.S.C. § 1391(b) because the Defendants are the District of Columbia, DC DOT, and DC DOT employees and Ms. Battle is employed by the District in the District.
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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; the plaintiff’s residence alone does not establish venue.

Austin v. State of California, San Francisco Superior Court · filed 2020-02-05(b)

Plaintiff resides within this judicial district,1 but is not in custody, and none of the Defendants reside in this district.2 In addition, the claims in the complaint arose in connection with family court proceedings in San Francisco Superior Court, (see Doc. 1 at 1), which is located in the San Francisco Division of the Northern District of California. Therefore, Plaintiff’s suit should have been filed in the United States District Court for the Northern District of California, San Francisco Division.
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Section 1391(b) permits a civil action in a district where a defendant resides, where a substantial part of the relevant events occurred, or, if neither basis provides a district, where a defendant is subject to personal jurisdiction.

Bordages v. Thorne · filed 2020-02-06(b)(1)–(3)

Venue is improper pursuant to § 1391(b)(1) and (2) because Thorne does not reside in the Western District of Tennessee and no part of the events giving rise to Plaintiff’s Complaint occurred in the Western District of Tennessee. Furthermore, venue is improper pursuant to § 1391(b)(3) because as previously explained, Thorne is not subject to personal jurisdiction in the Western District of Tennessee.
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Section 1391(b) does not permit venue 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.

Hurt v. D.C. Board of Parole · filed 2020-02-20(b)

Plaintiff resides in the District of Columbia. Both defendants also reside in the District of Columbia. Moreover, there is absolutely no indication that any part of the events or omissions giving rise to this claim occurred in the Eastern District of Missouri. In short, none of the requirements of § 1391 are present in this case. Therefore, venue in the Eastern District of Missouri is not proper.
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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.

Borges v. Schenectady County Jail · filed 2020-02-27(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) does not establish venue in a district where none of the events giving rise to the claim occurred.

Foley, David v. Zabble · filed 2020-03-04(b)(2)

Defendants thus have proven that venue is not proper in this court by virtue of § 1391(b)(2).
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Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.

Delvalle v. Annucci · filed 2020-03-12(b)(1) and (b)(2)

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

United States v. Engen · filed 2020-05-14(b)(2)

However, Plaintiff’s Complaint makes clear that venue is proper in the “judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated.” 28 U.S.C. § 1391(b)(2) (cited at Dkt. #1 at ¶ 4).
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Section 1391(b)(1)-(2) permits venue where a substantial part of the events occurred, or where a defendant resides if all defendants reside in the same state.

Jameson v. Dickson · filed 2022-03-04(b)(1)-(2)

Rather, venue is proper in the District of New Jersey where the underlying events occurred and where the Defendants likely reside.
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Section 1391(b) does not permit venue in a district where the defendant does not reside and no substantial part of the events giving rise to the claim occurred, when another district is available.

Bryceland v. McFarland · filed 2022-03-04(b)

Because Plaintiff does not allege that 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 Section 1391(b).
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Section 1391(b) permits venue in a district where the defendant resides or a substantial part of the events giving rise to the claim occurred.

Quiroz v. UR Medicine St. James Hospital · filed 2023-01-23(b)(1), (2)

Because Defendant is located in Steuben County, and the events giving rise to Plaintiff’s claims occurred in Steuben County, 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) permits venue in a district where a defendant resides when all defendants reside in the same state.

Stennette v. New York Department of Social Services Human Resources Administration · filed 2023-01-24(b)(1)

Thus, under Section 1391(b)(1), this court and the United States District Court for the Eastern District of New York are both proper venues for this action.
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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.

Eustade v. Eustade · filed 2023-01-31(b)(2)

Even if the Court did assume that Defendants reside in this District and that venue is proper here under Section 1391(b)(1), because the events giving rise to Plaintiff’s claims occurred at Brookdale Hospital, venue would also be proper under Section 1391(b)(2) in the Eastern District of New York.
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Section 1391(b) places venue in a district where a defendant resides or a substantial part of the events giving rise to the claim occurred, subject to its fallback rule.

Dunbar v. Dahlberg · filed 2023-02-27(b)

In this case, no defendant resides in this district, and plaintiff’s claims arose in Del Norte County in the Northern District of California.
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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.

State of Arkansas v. Hankins · filed 2023-02-27(b)

Plaintiffs does not assert any defendant resides within the Southern District of California and, according to his allegations, the events giving rise to his action occurred in Texarkana, Arkansas.
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Section 1391(b) does not establish venue in a district merely because federal agencies there oversee private defendants involved in events elsewhere.

Cox v. Dewees · filed 2023-03-05(b)

Moreover, federal governmental oversight of a private entity does not establish venue in the District of Columbia for events that occurred elsewhere and involved defendants located elsewhere.
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Section 1391(b) does not permit venue in a district where no defendant resides and no substantial part of the events giving rise to the claim occurred.

Machie v. Pinkett · filed 2023-03-23(b)

Venue is not proper in this Court. None of the defendants resides in Maryland and, insofar as the Court can discern the events giving rise to Machie’s claims, none occurred in Maryland.
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Venue for suits against legislative branch officials

Section 1391(e) does not establish venue in the plaintiff’s district for this suit against legislative branch officials.

Shaffer v. Clinton · filed 1999-07-02(e)

Plaintiffs state venue in Colorado is correct under 28 U.S.C. § 1391(e). ... Plaintiffs have failed to establish the District of Colorado is the appropriate venue for this action against the legislative defendants. Instead, the legislative defendants have shown that venue is improper in Colorado and that the District of Columbia is the proper venue.
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Section 1391 places venue where the defendants reside or the claim arose; an official sued in an official capacity resides, for venue purposes, where the official performs those duties.

Guillen v. Basse Case transferred to the Western District of Texas, Pecos Division. · filed 2023-01-26

As Fort Stockton, Texas is located within the jurisdictional boundaries of the United States District Court for the Western District of Texas, venue in the Eastern District of Texas is not proper.
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Venue for claims added by amendment

Section 1391(b) requires venue to be proper for each new claim in a proposed amendment; an amendment is futile when none of its venue grounds applies.

Amaker v. Haponik · filed 2000-12-22(b)

In addition, venue must be proper for each of the new claims raised. ... None of the three statutory standards for venue can give Mr. Amaker’s new claims a home in the Southern District of New York, and, therefore, amendment would be futile because these claims cannot survive a motion to dismiss for improper venue.
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Section 1391(b) requires a proper venue for claims against a defendant a plaintiff seeks to join.

Lewis-Davis v. Baltimore County Public Schools Infants & Toddlers Program · filed 2021-04-30(b)

However, even if there is a common question of law or fact as to Gloria’s Place, this District is not a proper venue for claims against the shelter.
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Corporate residence of sole proprietorships

Section 1391(c)'s corporate residence rule does not extend to a sole proprietorship merely because it sells products nationwide.

Hsin Ten Enterprise USA, Inc. v. Clark Enterprises · filed 2000-12-29(c)

broad geographic distribution does not convert a small sole proprietorship into a corporation. ... Nor does it convert Clark to the functional equivalent of a corporation.
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Venue for administrative forfeiture suits

Section 1391's general venue provisions govern an Administrative Procedure Act suit challenging a forfeiture.

Don Ameche Foehl, Sr. v. United States · filed 2001-02-01

We therefore consider this suit as governed by the broader venue provisions of 28 U.S.C. S 1391 and 28 U.S.C. S 1406.
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Venue in insurance coverage actions

In an insurance coverage action, venue under § 1391(a)(2) is assessed by looking to the underlying events for which coverage is sought.

Carolina Casualty Co. v. Data Broadcasting Corp. · filed 2001-07-26(a)(2)

In an insurance coverage action, to establish venue via section 1391(a)(2), a court looks to the underlying events for which coverage is sought.
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In an insurance coverage action, § 1391(b)(2) permits venue based on the underlying events for which coverage is sought.

Colony Insurance Company v. Progressive Casualty Insurance Company · filed 2021-03-31(b)(2)

Moreover, all acts and omissions relevant to the underlying tort claim transpired in Maryland. Accordingly, under the prevailing venue analysis in this district, venue proves improper.
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Section 1391(b)(2) bases venue for an insurance coverage action on where the events giving rise to the coverage claim occurred.

WEST BEND INSURANCE COMPANY v. UNITED STATES OF AMERICA CHESS FEDERATION · filed 2025-09-16(b)(2)

Second, under Section 1391(b)(2), the Court finds that a “substantial part of the events” giving rise to West Bend’s claim occurred outside the District of New Jersey.
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Tax Court appeals

Section 1391 does not govern appellate review of Tax Court decisions.

Doyel v. Comm'r · filed 2004-02-10

Contrary to petitioner’s assertion, it is section 7482, and not 28 U.S.C. section 1391 (2000), that provides the Courts of Appeal with jurisdiction to review our decisions.
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Pleading venue

Section 1391(a) identifies proper venue for diversity actions but does not require a complaint to state why venue is proper.

Blacksmith Investments, LLC. v. Cives Steel Co. · filed 2005-03-16(a)

However, 28 U.S.C. § 1391(a) merely identifies the proper venue for diversity actions; it does not impose any specific pleading requirements.
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Section 1391(b) requires a plaintiff to allege facts showing that the chosen district is a proper venue.

Bell v. KMG Management Prestige · filed 2022-04-04(b)

Because Bell fails to properly allege venue and subject matter jurisdiction, and she fails to state a claim upon which relief may be granted, the Court DISMISSES her complaint WITHOUT PREJUDICE.
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Section 1391(b) requires a plaintiff to plead facts showing that venue is proper in the chosen district.

Kemp v. Beirami · filed 2023-05-19(b)

Therefore, Plaintiff has not adequately plead that venue is proper in the Southern District of California.
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Section 1391(b) requires a complaint to allege facts connecting venue to the district, such as a defendant’s residence or a substantial part of the events giving rise to the claim.

Kemp v. Kuttler · filed 2023-07-17(b)

Therefore, Plaintiff has not adequately plead that venue is proper in the Southern District of California.
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Section 1391(b) requires facts showing that a defendant resides in the district or that a substantial part of the events giving rise to the claim occurred there.

McCoy v. The State of Missouri · filed 2023-08-29(b)

First, plaintiff has not properly alleged venue. A civil action may be brought only in: (1) a judicial district where any defendant resides, if all defendants reside in the same state; (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred; or (3) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought. See 28 U.S.C. § 1391(b).
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Section 1391(b)(1) and (2) permit venue where all defendants reside in the forum state and one resides in the district, or where a substantial part of the relevant events, omissions, or property is in the district.

Scales v. American Web Coders · filed 2023-10-10(b)(1), (b)(2)

Thus, he does not allege facts sufficient to show that this court is a proper venue for this action under Section 1391(b)(1). In addition, while Plaintiff alleges that he resides in New York County, within this judicial district, he alleges no facts showing where a substantial part of the events or omissions giving rise to his claims occurred or where a substantial part of property that is the subject of the action is situated. Thus, he does not allege facts sufficient to show that this court is a proper venue for this action under Section 1391(b)(2).
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Section 1391(b)(1) and (2) require facts showing qualifying defendant residence or a substantial connection between the district and the events or property at issue to establish venue.

Scales v. Web Design Gator · filed 2023-10-10(b)(1), (b)(2)

Thus, he does not allege facts sufficient to show that this court is a proper venue for this action under Section 1391(b)(1). In addition, while Plaintiff alleges that he resides in New York County, within this judicial district, he alleges no facts showing where a substantial part of the events or omissions giving rise to his claims occurred or where a substantial part of property that is the subject of the action is situated. Thus, he does not allege facts sufficient to show that this court is a proper venue for this action under Section 1391(b)(2). Accordingly, the Court grants Plaintiff leave to file an amended complaint alleging facts showing why this court is a proper venue for this action.
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Section 1391(b) requires a plaintiff to allege facts showing that venue is proper in the chosen district.

Kleiber v. Virani · filed 2024-04-21(b)

In addition, Plaintiff fails to allege facts showing that venue is proper in Oregon.
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Section 1391(b) requires facts supporting venue in the chosen district.

Oravetz v. Icicle Seafoods · filed 2025-08-02(b)

No facts support a conclusion that venue in Idaho is appropriate.
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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; a plaintiff must allege facts supporting venue in the chosen district.

(PS)Lopez · filed 2026-01-15(b)

Under 28 U.S.C. § 1391(b), venue is proper in: ... Plaintiff has not alleged that Defendant resides in this District, or that any events giving rise to her claim occurred in this District.
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Under Section 1391(b)(1) and (2), unsupported, conclusory assertions do not establish that a defendant resides in the district or that a substantial part of the events giving rise to the claim occurred there.

Amari J. Moody v. Broadview Federal Credit Union · filed 2026-02-03(b)(1), (b)(2)

Plaintiff’s vague and conclusory assertions, without any supporting facts, are insufficient to demonstrate that venue is proper in this district.
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Antitrust venue

Section 1391(b) and (c) cannot supplement the Clayton Act’s venue provision for domestic defendants in antitrust actions.

Howard Hess Dental Laboratories Inc v. Dentsply International, Inc. · filed 2007-09-26(b), (c)

Put another way, section 12 of the Clayton Act may not be supplemented with the general venue provisions of 28 U.S.C. 1391(b) and/or (c) for purposes of establishing venue for domestic defendants, and must be considered independently of those provisions.
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Section 1391 may establish venue in an antitrust suit using ordinary personal jurisdiction rules, but it cannot be paired with the Clayton Act’s nationwide service provision to bypass Section 12’s venue rules.

In re Blue Cross Blue Shield Antitrust Litigation (MDL No.: 2406) · filed 2014-06-18

First, an antitrust plaintiff may rely on traditional principles of personal jurisdiction and venue, demonstrating that the forum state’s long-arm statute provides for personal jurisdiction and that venue is proper under the general federal venue statute, 28 U.S.C. § 1391. ... However, in light of the court’s conclusion that the “integrated” approach is the correct rule of law, the venue issue will be assessed under Section 12’s venue provision (at least to the extent Plaintiffs have utilized Section 12’s nationwide service of process procedure).
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Section 1391(c)(2) treats a corporate defendant as residing in any district where it is subject to personal jurisdiction, and that rule may be applied alongside the Clayton Act’s nationwide jurisdiction provision in an antitrust case.

Hospital Authority of Metropolitan Government v. Momenta Pharmaceuticals, Inc. · filed 2017-03-21(c)(2)

The Court adopts the Magistrate Judge’s well-reasoned analysis, which follows the lead of other federal circuits that have concluded that the Clayton Act’s grant of nationwide jurisdiction in antitrust cases, 15 U.S.C. § 22 (“Section 12”), may be read in concert with the general civil venue statute’s provision establishing that a corporate defendant is considered to “reside” in any district in which it is subject to personal jurisdiction, 28 U.S.C. § 1391(c)(2). ... Accordingly, venue is permissible in this Court.
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Section 1391’s substantial-events test does not govern venue in a corporate antitrust action when Section 12 of the Clayton Act supplies the applicable transacts-business test.

United States v. Agri Stats, Inc. · filed 2024-05-28(b)(2)

The appropriate inquiry is not if a substantial part of the events giving rise to the claims occurred in Minnesota but rather whether Agri Stats transacts business in Minnesota to an extent that would make venue proper in this District.
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Copyright claims

Section 1391’s general venue rules do not govern copyright actions; § 1400(a) controls venue for those actions.

Belaustegui v. KC Media LLC · filed 2020-08-17

Venue in this action is controlled by the specific venue provision of 28 U.S.C. § 1400(a), which applies to copyright actions, as opposed to the general federal venue statute, 28 U.S.C. § 1391.
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Section 1391(b)’s general venue rules do not govern copyright infringement actions because § 1400(a) supplies the exclusive venue rule.

Nu Image, Inc. v. Does 1-23,322 · filed 2011-07-29(b)

However, when copyright infringement is the sole claim being alleged, it is misleading, and arguably disingenuous, to assert that venue may be proper under section 1391(b), the general venue statute, when section 1400(a) is the exclusive venue statute for copyright infringement actions.
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Section 1391(b) does not govern venue for copyright claims, which are governed by § 1400(a).

Allison v. Wise · filed 2007-12-26(b)

In the alternative, Wise contends that venue is not proper in this district, citing 28 U.S.C. § 1391(b). Claims under the Copyright Act, however, are governed by the venue provisions of 28 U.S.C. § 1400(a), which provides that suits thereunder may be instituted "in the district in which the defendant or his agent ... may be found.”
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Section 1391’s general venue rule does not govern copyright infringement claims; Section 1400(a) governs their venue exclusively.

Williams v. Tava Ventures Inc · filed 2024-02-14

Plaintiffs allege that “[v]enue is proper in this District pursuant to 28 U.S.C. § 1391.” Compl. ¶ 3; Am. Compl. ¶ 3. Venue for copyright infringement claims, however, is governed exclusively by a special provision of the Copyright Act, which provides that infringement claims may be brought “in the district in which the defendant or his agent resides or may be found.”
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Section 1391 does not govern venue for federal copyright infringement claims; Section 1400(a) does.

Jackson v. Warner Music Group Corp. · filed 2024-06-11

Plaintiff asserts that this court is a proper venue for this action under 28 U.S.C. § 1391 (id. at 13, 16), but that is not the applicable venue provision for his claims.
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Section 1391 does not govern venue for federal copyright infringement claims; Section 1400(a) does.

Jackson v. Destiny's Child · filed 2024-06-11

Plaintiff does not allege where any defendant or his/her/its agent resides or may be found, and asserts that this court is a proper venue for this action under 28 U.S.C. § 1391 (ECF 10, at 1), but that is not the applicable venue provision for his claims.
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FTCA claims

Section 1391(e) does not govern venue for FTCA claims against the United States; § 1402(b) governs those claims.

Spotts v. United States · filed 2008-06-23(e)

As noted above, Plaintiffs’ Second Amended Complaint erroneously alleges that, pursuant to 28 U.S.C. § 1391(e), venue for this action is proper in the District of Columbia because the BOP resides in the District. ... Plaintiffs do not challenge Defendant’s correct assertion that the appropriate standard for determining venue in FTCA cases is contained in 28 U.S.C. § 1402(b), Def.’s Mot. at 3, and that under that provision, Plaintiffs’ FTCA claims may be brought “only in the judicial district where the plaintiff resides or wherein the act or omission complained of occurred.”
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Section 1391(a)'s general venue rule does not apply to FTCA claims because the FTCA has its own venue provision.

KALAWA v. UNITED STATES OF AMERICA · filed 2020-07-02(a)

Because the FTCA contains its own venue provision, the general venue provision found at 28 U.S.C. § 1391(a), which states that venue is proper in “a judicial district where a substantial part of the events or omissions giving rise to the claim occurred,” is not applicable here.
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Plaintiff’s choice of venue

Section 1391 governs a plaintiff’s choice of venue when no special venue statute applies, but that choice remains subject to transfer under § 1404(a).

In Re Volkswagen of America, Inc. · filed 2008-10-10

When no special, restrictive venue statute applies, the general venue statute, 28 U.S.C. § 1391, controls a plaintiff’s choice of venue. ... Thus, while a plaintiff has the privilege of filing his claims in any judicial division appropriate under the general venue statute, § 1404(a) tempers the effects of the exercise of this privilege.
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Section 1391(b) does not make a plaintiff’s location or litigation preferences relevant to whether venue is proper.

Williams v. Eckstein · filed 2021-11-18(b)

But a plaintiff’s location and litigation preferences are not relevant to whether venue is proper under 28 U.S.C. § 1391(b).
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Section 1391(b) does not make a plaintiff’s location or litigation preferences relevant to whether venue is proper.

Williams, Derek v. Eckstein, Scott · filed 2021-11-18(b)

But a plaintiff’s location and litigation preferences are not relevant to whether venue is proper under 28 U.S.C. § 1391(b).
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Section 1391(b) does not make a plaintiff’s anticipated relocation a basis for venue in another district.

(PC) Dennis v. Doser · filed 2022-10-25(b)

To the extent Plaintiff wishes to change venue to a court in San Diego based on his anticipated re-location, venue is only proper before this Court. Title 28 U.S.C. § 1391(b) provides venue is appropriate where any defendant resides, where a substantial part of the events or omissions giving raise to the claim occurred, or any district in which a defendant is subject to the personal jurisdiction of the court with respect to the action.
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Section 1391(b) does not permit a plaintiff to choose a district based on perceived judicial bias when the events and parties are in another district.

Gage v. County of Somerset · filed 2023-01-13(b)

All events underlying this action took place in New Jersey, and all parties were residents of New Jersey. Gage’s subjective concerns about bias from courts in New Jersey — based solely on unfavorable prior rulings against him — does not permit venue in the district of his choosing.
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Venue for Bivens claims

Section 1391 governs venue for Bivens actions and provides similar venue rules for actions against federal officers or employees.

Van Kush v. 10th Circuit Executive · filed 2019-12-31(b), (e)

None of these is applicable here nor are the provisions of § 1391(e) which contain similar provisions for venue in actions against officers or employees of the United States.
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Section 1391(b) permits a Bivens claim in a district where a substantial part of the events giving rise to it occurred.

Hemmings v. United States of America · filed 2009-04-15(b)

Because none of the events giving rise to the complaint occurred in the District of Columbia, this judicial district is not the proper venue for litigating either the Bivens or the FTCA claim.
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Section 1391 governs venue for ADEA claims, including those brought alongside Title VII claims.

Shahin v. Geithner · filed 2012-06-11

Venue for Title VII claims is governed by 42 U.S.C. § 2002e-5(t)(3) and venue for ADEA claims is governed by the general venue statute, 28 U.S.C. § 1391.
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Section 1391(b) governs venue for Bivens damages claims against federal officers sued in their individual capacities.

Coltrane v. Lappin · filed 2012-08-15(b)

Because “§ 1391(e) applies only to suits against government officers in their official capacities, [and] not to Bivens actions,” Cameron, 983 F.2d at 256, the controlling venue provision here is § 1391(b).
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Section 1391(b) places venue for personal-capacity Bivens claims in a district that satisfies its defendant-residence rule or where a substantial part of the events occurred.

Mikhaylov v. United States · filed 2014-07-07(b)

Because none of the individual agents allegedly live in the same state, let alone in New York (Am. Compl. ¶¶ 4-7), the proper venue for these claims appears to be the Central District of California, where they arrested and confined Mikhaylov.
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Section 1391(b)(2) permits venue for a Bivens claim where a substantial part of the events giving rise to the claim occurred.

Dastmalchian v. Department of Justice · filed 2014-10-20(b)(2)

In the present case, only subsection (2) would apply, making the proper venue for plaintiff’s Bivens claims the Central District of California.
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Section 1391(e) allows venue for suits against federal agencies or officers acting in their official capacity, but does not apply to Bivens actions.

Pinson v. U.S. Department of Justice · filed 2014-11-21(e)

Plaintiff asserts venue for his Bivens claims based on 28 U.S.C. § 1391(e), which permits suits against government agencies or officers acting in their official capacity to be brought in any district in which a named defendant resides; however, section 1391(e) is inapplicable for Bivens actions.
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Section 1391(e) permits venue for an ADEA claim against a federal official where the defendant resides, substantial events giving rise to the claim occurred, or the plaintiff resides.

Webster v. Carter · filed 2017-08-22(e)

Under that provision, venue for Plaintiff’s age discrimination claim is proper: 1) where a defendant in the action resides; 2) where a substantial part of the events giving rise to the claim occurred; and 3) where the plaintiff resides. 28 U.S.C. § 1391(e).
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Section 1391(b) governs venue for Bivens claims; the complaint must allege facts showing that venue is proper in the chosen district.

Williams v. United States of America · filed 2019-07-03(b)

Plaintiff fails to allege facts showing that, in connection with the FTC case, venue is proper in this Court under § 1391(b) or the FTCA venue statute.
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Section 1391(b) does not permit venue for a § 1981 claim in a district where no defendant is alleged to reside and none of the events giving rise to the claim occurred.

Vukic v. Universal Protection Service LLC · filed 2020-03-02(b)

As noted above, this Court is a proper venue for Plaintiff’s Title VII claims, but not for her § 1981 claims.
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Section 1391(b) governs venue for Bivens claims; venue was improper where the defendants did not reside, no substantial part of the relevant events occurred, and the defendants were not subject to personal jurisdiction.

Sanchez-Mercedes v. Bureau of Prisons · filed 2020-04-10(b)

The Government does not make the argument, but this District is the wrong venue for the Bivens claims too. The relevant venue statute for Bivens claims is 28 U.S.C. § 1391(b). Cameron, 983 F.2d at 257. Under that provision, venue is proper in this District if Patterson and Wilson reside here, 28 U.S.C. § 1391(b)(1), if “a substantial part of the events or omissions giving rise to the claim occurred” here, id. § 1391(b)(2), or if Patterson or Wilson “is subject to the court’s personal jurisdiction” here, id. § 1391(b)(3). But for reasons the Court has already given, none of these is true.
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Section 1391(b) does not provide venue for Bivens claims arising at federal prisons outside the district when the complaint identifies no basis for venue in the district.

Tuttle v. United States · filed 2020-06-29(b)

Because neither of those institutions is located within this district, venue in this Court is neither proper nor convenient. See 28 U.S.C. § 1391(b) (Bivens); 28 U.S.C. § 1402(b) (FTCA).
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Section 1391(b) governs venue for individual-capacity Bivens claims when no special venue statute applies; venue is proper where the defendants reside or a substantial part of the events occurred.

Tucker v. USA · filed 2020-07-02(b)

Since there is no special venue statute for actions asserting such claims, 28 U.S.C. § 1391(b) applies. ... Thus, the Eastern District of Virginia is the proper venue for Tucker’s remaining claims, and, as a result, the Court will transfer this action.
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Section 1391(b) places venue for claims concerning conditions at an Arizona prison in the District of Arizona.

Grandinetti v. Institutional Grievance Officers, DPS-HI · filed 2020-08-03(b)

Moreover, Grandinetti’s claims regarding mental health examinations or appearing before the parole board in Arizona are properly raised in the United States District Court for the District of Arizona, where Saguaro Correctional Center is located and venue for these claims lie. See 28 U.S.C. § 1391(b).
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Section 1391(b) permits venue for a Bivens action where the defendants reside or a substantial part of the events giving rise to the claim occurred.

SMITH v. EBBERT · filed 2021-05-18(b)

As there is no basis for venue in this district, and in light of Plaintiff’s request that this case be transferred to the proper venue, the Court will transfer this case to the United States District Court for the Middle District of Pennsylvania, where the events giving rise to his claims occurred and where the Defendants are located.
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Section 1391(b) permits venue for a Bivens claim where a defendant resides if all defendants reside in the same state, where a substantial part of the events occurred, or where a defendant may be found if no other district is available.

Embrey v. United States · filed 2022-02-09(b)

A cause of action under Bivens and its progeny may be brought in a judicial district where: (1) any defendant resides if all defendants reside in the same state; (2) a substantial part of the events or omissions giving rise to the claim occurred; or (3) any defendant may be found if there is no district in which the action may otherwise be brought. 28 U.S.C. § 1391(b); see Coltrane v. Lappin, 885 F. Supp. 2d 228, 234 (D.D.C. 2012). As to the first, no evidence suggests that all Defendants reside in the District. As to the second, none of the alleged events giving rise to Embrey’s claims took place in the District. Embrey’s allegations arise from conduct that occurred while incarcerated outside of the District. As to the third, Embrey provides no argument as to why he cannot file this lawsuit in a district where he once was incarcerated. Adding that all up means that the District does not present a proper venue for Embrey’s Bivens claims.
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Section 1391(b) permits venue for a Bivens claim where all defendants reside or where a substantial part of the events giving rise to the claim occurred.

Strong v. United States · filed 2024-11-26(b)

The Court agrees with the Magistrate Judge that the most appropriate venue is the United States District Court for the Eastern District of California, where all Defendants reside and where all the events underlying Plaintiff’s claims occurred.
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Section 1391(b) permits venue for a Bivens claim where all defendants reside or where a substantial part of the events giving rise to the claim occurred.

(PC) Strong v. Brown · filed 2024-11-26(b)

The Court agrees with the Magistrate Judge that the most appropriate venue is the United States District Court for the Eastern District of California, where all Defendants reside and where all the events underlying Plaintiff’s claims occurred.
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Section 1391(b) governs venue for Bivens claims and permits suit where a substantial part of the events giving rise to the claim occurred.

Esmaeli v. Tejada · filed 2025-05-13(b)

Venue for a Bivens claim is determined by 28 U.S.C. § 1391(b), which provides: “A civil action wherein jurisdiction is not founded solely on diversity of citizenship may . . . be brought only in (1) a judicial district where any defendant resides, if all defendants reside in the same State, (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred . . . or (3) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought.”
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Section 1391(b) governs venue for Bivens claims.

Nguyen v. Marshall · filed 2025-09-02(b)

Venue for Plaintiff’s Bivens claims is governed by Section 1391(b).
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Congressional investigations

Section 1391(b)(2) does not make a district a proper venue for a private civil suit merely because Congress investigates the underlying events there.

Estate of Himoud Saed Atban v. Blackwater USA · filed 2009-04-27(b)(2)

Nor is the Court aware of any authority supporting the notion that a congressional investigation somehow renders the District of Columbia an appropriate venue for lawsuits filed by private individuals. If that were the case, virtually any private dispute with public implications that attract congressional attention could be litigated in this jurisdiction. The Court declines to read § 1391(b)(2) in such a grossly overbroad manner.
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Venue for trademark claims

Section 1391(b)(2) permits venue in a trademark infringement suit where consumers are likely to be confused by the accused goods, even if the defendant’s sales in the district are modest.

Adidas America, Inc. v. Cougar Sport, Inc. · filed 2016-03-14(b)(2)

The general venue statute, 28 U.S.C. § 1391(b), governs trademark claims. ... Because consumers in this District are likely to be confused by the allegedly infringing merchandise, venue is proper under 29 U.S.C. § 1391(b).
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Section 1391(b)(1), as applied by the court, permits venue for trademark claims when uncontroverted allegations establish even modest sales of infringing products in the district.

Allstar Marketing Group, LLC v. Your Store Online, LLC · filed 2009-08-10(b)(1)

As courts have found that only a “modest” amount of sales of infringing product is sufficient to support venue in a particular district, the court concludes that plaintiffs’ trademark claims are properly brought in this district under § 1391(b)(1).
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Section 1391(b)(1)-(2) governs venue for Lanham Act claims based on defendants’ residence or where a substantial part of the events occurred.

Allchem Performance Products, Inc. v. Aqualine Warehouse, LLC · filed 2012-07-13(b)(1)-(2)

Defendants are correct in applying the. general venue statute, 28 U.S.C. § 1391(b)(l)-(2), here to the Lanham Act claims. With regard to both claims, venue in the Southern District of Texas is improper and proper in the Phoenix Division of the District of Arizona.
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Section 1391(b)(2) does not establish venue for a trademark infringement claim merely because an allegedly infringing website is accessible in the district, absent sales or activities aimed there.

KAIA Foods, Inc. v. Bellafiore · filed 2014-10-03(b)(2)

Although internet users in this district can access Defendant’s website, there is no evidence that any orders have ever been placed by purchasers in this district. ... Under these facts, and for the reasons discussed above, the Court concludes that venue is improper in this district.
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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, including where the alleged infringement caused injury.

Helmer, Jr. v. Beasley, Allen, Crow, Methvin, Portis & Miles, P.C. · filed 2020-09-03(b)(2)

First, venue is proper in the Southern District of Ohio since it is where “a substantial part of the events . . . giving rise to the claim occurred.” 28 U.S.C. § 1391(b)(2). As Plaintiff has established, the tortious injury resulting from the alleged infringement occurred in this district.
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Section 1391(b) does not make a district a proper venue for a trademark infringement claim when the defendant is not alleged to reside there and no substantial part of the events giving rise to the claim is alleged to have occurred there.

Yang v. Chee Ray, LLC · filed 2021-02-18(b)

Because Yang does not allege that the defendant resides in this judicial district or that a substantial part of the events or omissions giving rise to the claims arose in this judicial district, this Court is not a proper venue for Yang’s claims of trademark infringement under § 1391(b).
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Section 1391(b)(2) permits venue for a Lanham Act claim in a district where consumers are likely to be confused by the accused goods, even when sales there are modest.

Corker v. Costco Wholesale Corporation · filed 2022-02-14(b)(2)

However, this Court need not reach whether Hoover’s reasoning applies here, because, although defendant’s sales of its Kona Blend coffee in this district were a modest portion of its ... total sales, venue is proper under § 1391(b)(2).
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Section 1391(b)(2) measures venue in trademark infringement cases by where consumer confusion occurs, rather than where the plaintiff suffers injury.

Soltura, LLC v. Cerveceria La Tropical USA, LLC · filed 2023-10-20(b)(2)

Soltura’s cases do not persuade this Court to depart from the cases holding that venue in trademark cases should be measured based on where consumer confusion occurs, not where injury is suffered.
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Section 1391(b)(2) permits venue for a trademark infringement claim when allegedly infringing sales occurred in the district.

Vicious Brands, Inc. v. Face Co., LLC · filed 2024-11-12(b)(2)

Because at least some of Defendants’ allegedly infringing sales appear to have occurred in this district, Defendants’ Motion is DENIED to the extent that it seeks dismissal for improper venue.
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In a trademark infringement case, venue under § 1391(b)(2) depends on where the alleged passing off occurred; the location of the plaintiff’s own sales does not establish venue.

Purple Innovation, LLC v. Waykar, Inc. · filed 2025-08-29(b)(2)

Purple’s allegation about the location of its own sales is irrelevant to this inquiry. See Jenkins, 321 F.3d at 1371-72, citing Woodke, 70 F.3d at 985. Accordingly, the Complaint does not establish that venue is proper under 28 U.S.C. § 1391(b)(2).
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Venue when no other district is available

Section 1391(b)(3) permits venue where a defendant may be found if no other district can hear the action against all defendants.

Hogar Crea, Inc. v. Hogar Crea International of Connecticut, Inc. · filed 2009-08-10(b)(3)

In any event, venue is proper under part three, because there is no other district in which jurisdiction over both HCMA and HCCT may be had.
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Section 1391(b)(3) permits venue where a defendant is found if there is no district in which the action may otherwise be brought.

Patel v. Phillips · filed 2013-03-28(b)(3)

Pomeroy was found in this district and was personally served here, and venue therefore is proper under § 1391(b)(3).
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Section 1391’s fallback provision permits venue in a district where a defendant is subject to personal jurisdiction when no other district qualifies.

RMS Titanic, Inc. v. Zaller · filed 2013-10-17(b)(3)

The Court finds venue in this court to be proper. Plaintiffs and Defendants Zaller, TZ, and Imagine-Georgia are all Georgia citizens, and Plaintiffs shall conduct discovery to determine whether the remaining Defendant, Imagine-Nevada, is a proper defendant in this action. Regardless of whether Imagine-Nevada ultimately remains a party to this lawsuit, venue is proper with respect to the Georgia parties. The Court also finds venue to be proper for all Defendants. 28 U.S.C. Section 1391(3). Defendants’ motion to dismiss for improper venue is denied.
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Section 1391(b)(3) permits venue based on a defendant’s personal jurisdiction only when no other district is available under the earlier venue provisions.

Liebman v. Deutsche Bank National Trust Company · filed 2014-02-11(b)(3)

Here, venue would be proper pursuant to 28 U.S.C. § 1391(b)(2) in the Southern District of Florida. Plaintiffs live in that district and they experienced the allegedly fraudulent and malicious billing procedures there. Accordingly, given that another district exists where this action may be brought, venue is not appropriate here under the safety net provision of 28 U.S.C. §1391(b)(3).
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Section 1391(b)(3) permits venue based on personal jurisdiction only when no other district provides proper venue.

Williams v. Wells Fargo Bank, N.A. · filed 2014-06-26(b)(3)

Because there is another district in which venue would be appropriate, the Court need not determine if the requirements of personal jurisdiction have been met with respect to the Defendants.
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Section 1391(b)(3) permits venue in a district where a defendant is subject to personal jurisdiction if no other district provides proper venue.

Willis Electric Co., Ltd. v. Polygroup Limited · filed 2020-02-03(b)(3)

“If there is no district in which an action may otherwise be brought,” venue is proper in “any judicial district in which any defendant is subject to the court’s personal jurisdiction.” 28 U.S.C. § 1391(b)(3). Polygroup has not identified an alternative forum in which venue would be proper.2 As such, venue in this Court is proper under Section 1391(b)(3) because, as addressed above, Polygroup is subject to this Court’s personal jurisdiction.
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Section 1391(b)(3) permits venue where a defendant is subject to personal jurisdiction if no district qualifies under the other venue grounds.

Ayasli v. Sezgin Baran Korkmaz, Kamil Feridun Ozkaraman, Fatih Akol, SBK Holdings A.S., SBK Holdings, USA, Inc., · filed 2020-07-27(b)(3)

But venue would still be proper in California under § 1391(b)(3).
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Section 1391(b)(3) permits venue based on a defendant’s personal jurisdiction only if the action cannot otherwise be brought in another district.

Coutee v. USAA General Indemnity Co · filed 2020-10-29(b)(3)

Third, because the Court finds that this action may otherwise be brought in the Western District of Louisiana, the Court need not determine whether Defendant was subject to this Court’s personal jurisdiction at the time the action was commenced. For these reasons, the Court concludes that venue is improper in the Eastern District of Louisiana.
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Section 1391(b)(3) permits venue based on personal jurisdiction only when no district qualifies under subsection (b)(1) or (b)(2).

Rajapakse v. Escrow.Com · filed 2021-06-17(b)(3)

Since Plaintiff could file her lawsuit in other districts under Section 1391(b)(1) or (b)(2), Section 1391(b)(3) is inapplicable in the instant lawsuit, and personal jurisdiction does not establish venue here.
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Section 1391(b)(3) does not establish venue when the plaintiff could have brought the action in another judicial district.

Chavez v. Hesler · filed 2022-12-05(b)(3)

Because there is a proper judicial district in which the plaintiff could have brought (and did bring) the claim he raises in this lawsuit, §1391(b)(3) does not apply.
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Section 1391(b)(3) permits venue based on personal jurisdiction only when the action cannot otherwise be brought in any district under the other venue provisions.

Doe 1 v. Congregation of the Sacred Hearts of Jesus and Mary · filed 2023-01-13(b)(3)

Section 1391(b)(3) applies only if “there is no district in which an action may otherwise be brought as provided” in the other subsections of the general venue provision. It is clear from the FAC, however, that venue would be proper in at least the District of Massachusetts.
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Section 1391(b)(3) permits venue based on a defendant’s personal jurisdiction only if no district is available under the section’s other venue provisions.

Kumaran v. National Futures Association · filed 2024-05-13(b)(3)

Second, Plaintiffs’ argument regarding § 1391(b)(3) ignores that § 1391(b)(3) applies only “if there is not district in which an action may otherwise be brought as provided in this section.” 28 U.S.C. § 1391(b)(3). Plaintiffs have not presented an argument that supports the conclusion that venue is inappropriate in any other district under §§ 1391(a) or (b).
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Section 1391(b)(3) allows venue based on a defendant’s personal jurisdiction only when no district qualifies under § 1391(b)(1) or (2).

Rindal v. Inslee · filed 2024-11-25(b)(3)

Third, § 1391(b)(3) only applies where venue cannot be brought pursuant to § 1391(b)(1) or (2). As discussed—and as Plaintiff asserted in his Second Amended Complaint—this is plainly not the case here.
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Section 1391(b)(3) permits venue only when no other district is available for the action.

Fitch v. McHenry · filed 2025-01-27(b)(3)

However, § 1391(b)(3) only applies where “there is no district in which an action may otherwise be brought,” and Fitch failed to demonstrate that his filings in other courts were dismissed for want of venue.
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Section 1391(b)(3) provides a venue fallback only when the action could not otherwise be brought in another district.

Brown · filed 2025-11-05(b)(3)

Venue is not proper in the Eastern District of Louisiana under § 1391(b)(3) because that provision applies only “if there is no district in which an action may otherwise be brought.”
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Venue in multiparty, multiforum litigation

Section 1391(g) governs venue only when district court jurisdiction is based on § 1369.

Laukus v. United States · filed 2010-03-08(g)

However, § 1391(g) is clearly inapplicable because it only governs venue in cases where the jurisdiction of the district court is based on 28 U.S.C. § 1369, which deals with multiparty, multiforum litigation.
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Venue for individual-capacity claims

Section 1391(b) does not permit venue for individual-capacity claims in a district where the defendants do not all reside, no substantial part of the events occurred, and another district is available.

Shipley v. Bureau of Prisons · filed 2010-08-05(b)

Venue is not proper in this district under any of the provisions of 28 U.S.C. § 1391(b) with respect to these defendants in their individual capacities: all of the defendants do not all reside in the District of Columbia, no substantial part of the events giving rise to plaintiffs claim took place here, and this is not a case in which no other district is available.
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Section 1391(b) permits venue in the District of Columbia for official-capacity claims against agency officials based there, but venue for individual-capacity claims must be assessed separately.

Shipley v. Bureau of Prisons · filed 2010-08-06(b)

Insofar as the BOP is headquartered in the District of Columbia and its Director and Administrator of National Appeals are named defendants in their official capacities, venue in this district is not improper.
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Section 1391(e) does not apply to damages suits against federal officials in their individual capacities.

Garcia v. United States · filed 2020-10-25(e)

However, “[s]ection 1391(e) only applies to actions in which the defendant is an officer or employee of the United States or any agency thereof acting in his official capacity or under color of legal authority. It does not apply to actions for money damages brought against federal officials in their individual capacities.” Gilbert v. DaGrossa, 756 F.2d 1455, 1460 (9th Cir. 1985). Plaintiff brings this action against the Talladega Defendants in their individual capacities. Accordingly, the Talladega Defendants, as well as Doe 3, are dismissed under Rule 12(b)(2) for lack of personal jurisdiction.
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Section 1391(e)(1) does not allow a plaintiff to establish venue based on the plaintiff’s residence for a damages suit against federal employees in their individual capacities.

Yarbrough v. Tooele County Detention Center · filed 2023-01-31(e)(1)

Section 1391(e)(1) does not apply in this lawsuit, which seeks monetary damages brought against federal employees in their individual capacities.
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Admiralty cases

Section 1391’s venue requirements for civil actions do not apply to admiralty cases.

Colonna's Shipyard, Inc. v. CITY OF KEY WEST, FLA. · filed 2010-08-27

28 U.S.C. § 1391, which describes the venue requirements for civil actions, does not apply to cases brought in admiralty, such as this matter.
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Section 1391(b)'s venue rules do not apply to admiralty cases.

Albert v. F/V Misty Dawn, Inc. · filed 2013-06-19(b)

Given that the venue provisions of § 1391(b) are inapplicable in this admiralty case, the Court instead determines venue pursuant to the discretionary standard set forth in § 1404.
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Section 1391(b) does not determine venue in an admiralty action, although § 1391(c)'s residency principles still apply.

Travelers Prop. Cas. Co. of Am. v. Ocean Reef Charters LLC · filed 2018-08-31(b)

Although § 1391(b) does not apply in determining the appropriate venue in a case proceeding under a federal court's admiralty jurisdiction, the Court sees no reason to conclude that the principles for determining a party's residency as set forth in § 1391(c) would apply with any less force in the admiralty context.
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Section 1391’s general venue rules do not apply in admiralty cases.

Supreme Rice, L.L.C. v. Turn Services, L.L.C. · filed 2020-07-29

The regular venue provisions in 28 U.S.C. § 1391 do not apply in admiralty cases.
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Section 1391(b) does not govern venue in civil actions under a district court’s admiralty jurisdiction.

Platina Bulk Carriers Pte Ltd. v. Praxis Energy Agents DMCC · filed 2021-09-10(b)

To start, this case arises under the Court’s admiralty jurisdiction and thus Section 1391(b) does not govern.
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Statutory interpleader

Section 1391’s general venue rules yield to the specific venue rule for statutory interpleader actions.

Mudd v. Yarbrough · filed 2011-04-06

Plaintiffs respond that, by its terms, the general venue statute, 28 U.S.C. § 1391, applies “except as otherwise provided by law” — and that this is an instance where the law provides otherwise. ... Plaintiffs correctly conclude that the general venue provision must yield to the interpleader venue provision.
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Section 1391(a)'s general venue rules yield to the specific venue rule for statutory interpleader actions.

Comerica Bank v. Schnizlein · filed 2020-04-27(a)

The interpleader venue statute is a specific instance where “the law provides otherwise.”
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Notes 7051–7200 of 8,639, oldest cases first.

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