28 U.S.C. § 1391
Venue generally: the cases that interpreted this section
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.
Location of events giving rise to an FDCPA claim
Section 1391(e)(1)(B) requires a substantial part of the events giving rise to the claim to occur in the district; general ties to the area do not establish venue.
Che · filed 2025-09-22(e)(1)(B)
Therefore, none of the facts that Plaintiff points to directly gave rise to his APA claim nor do they sufficiently allege substantial events that occurred in this specific district. Plaintiff has not carried his burden of alleging that a substantial part of the events giving rise to his claim occurred in this district.Read the full opinion on CourtListener →
Section 1391(b)(2) does not establish venue based on settlement negotiations that occurred after the events giving rise to the claims.
Shenzhen Mammotion Innovation Co., Ltd. v. Futuregen Technologies Inc. · filed 2025-10-15(b)(2)
Although the ensuing negotiations may have influenced the timing of this action, they did not give rise to the claims that Plaintiff asserts in its Complaint. Section 1391(b)(2) therefore provides no basis for venue in this district.Read the full opinion on CourtListener →
Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.
J.L. Turner Legal Association v. National Bar Association · filed 2025-10-15(b)
Venue is thus improper in this District, which is neither a District in which a defendant resides nor a District in which events giving rise to the claim occurred.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.
Kornegay · filed 2026-01-05(b)(2)
Plaintiff also alleges that all of the events giving rise to his claims took place at FCI Cumberland in Maryland, and venue therefore is not proper in this district under Section 1391(b)(2), based on the location where the events giving rise to the claims occurred.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue where a substantial part of the events giving rise to the claim occurred.
Archelus · filed 2026-01-07(b)(2)
As a result, from the face of the Complaints and supporting documents, venue may not be proper in this court under § 1391(b)(2). ... Plaintiff's Complaint filed in Case No. 25-cv-868 (Doc. 1-1) is DISMISSED for lack of venue.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claims occurred.
Mercado · filed 2026-01-16(b)(2)
Thus, because Queens County lies within the Eastern District of New York, see § 112(c), under Section 1391(b)(2), the United States District Court for the Eastern District of New York is a proper venue for Plaintiff’s claims under the ADEA, the FMLA, and under state law.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue in a judicial district where a substantial part of the events giving rise to the claim occurred.
Terry · filed 2026-01-28(b)(2)
Venue is proper, under Section 1391(b)(2), in the Eastern District of New York, where Plaintiff’s claims arose.Read the full opinion on CourtListener →
Section 1391(b)(2) does not establish venue in a district where none of the events underlying the claims occurred.
Jones · filed 2026-02-13(b)(2)
Accepting the allegations as true, none of the alleged wrongdoing occurred in New Mexico. The claims stem from events in a New York prison.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.
Korby · filed 2026-02-18(b)(2)
Venue is thus improper under § 1391(b)(2) because no substantial part of the events giving rise to the claims occurred in the Eastern District of Pennsylvania (EDPA).Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue where the leases underlying a claim were negotiated and executed, even if the alleged breach occurred elsewhere.
Kalkman Habeck Company v. APA Corporation · filed 2026-02-26(b)(2)
For the foregoing reasons, the Court concludes that while venue in the Eastern District of Oklahoma is not improper under 28 U.S.C. § 1391(b) because the negotiation and execution of the leases occurred in Oklahoma, dismissal is not warranted.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue where a substantial part of the events giving rise to a claim, including the injury, occurred.
Nichamin · filed 2026-03-16(b)(2)
And finally, because a substantial part of the events giving rise to the claim, namely the injury, occurred in this state, the Court finds venue is proper in the State and District of Colorado under 28 U.S.C. § 1391.Read the full opinion on CourtListener →
Section 1391(b)(2) requires a substantial part of the events giving rise to the claims to occur in the chosen district; manufacturing products there does not establish venue for misrepresentation claims arising from statements made elsewhere.
Walton · filed 2026-03-23(b)(2)
The amended complaint does not contain allegations of misrepresentations made to each named Plaintiff by Gore in this District. Accordingly, § 1391(b)(2) does not provide a basis for venue in the District of Maryland.Read the full opinion on CourtListener →
Section 1391(e)(1)(B) does not establish venue merely because a challenged rule was promulgated in the district when the events giving rise to the claim occurred elsewhere.
Su v. United States Department of Justice · filed 2026-04-02(e)(1)(B)
So even if Su would have no suit without this rule promulgated in Washington, that connection to his case is too “[p]heripheral” to establish venue in this district.Read the full opinion on CourtListener →
Section 1391(b)(2) permits venue in a district where a substantial part of the events giving rise to the claim occurred.
Burton · filed 2026-05-11(b)(2)
Here, the events giving rise to Plaintiff’s claims occurred in the Western District of Missouri, and venue is proper there.Read the full opinion on CourtListener →
Section 1391(b)(2) does not allow venue in a district where none of the alleged wrongdoing occurred and the claims stem from events elsewhere.
Johnson v. Gonzales · filed 2026-06-01(b)(2)
Subsection (b)(2) also does not apply. ... Accepting Johnson’s allegations as true, none of the alleged wrongdoing occurs in New Mexico. The claims stem from events in Colorado.Read the full opinion on CourtListener →
Section 1391(b)(2) focuses on the defendant’s activities giving rise to the claim when determining where venue is proper.
Steen v. Murray · filed 2013-06-28(b)(2)
In Woodke, the Eighth Circuit interpreted the phrase “events or omissions giving rise to the claim,” within § 1391(b)(2), to indicate that “Congress meant to require courts to focus on relevant activities of the defendant, not of the plaintiff.” ... The Southern District of Iowa applied a reasonable interpretation of Eighth Circuit precedent to the facts of this ease. Plaintiffs have not met their heavy burden of demonstrating that a previous order was clearly erroneous. Accordingly, the transfer Order (Filing No. 34) will not be disturbed.Read the full opinion on CourtListener →
Section 1391(a)(2) permits venue in a diversity action challenging an arbitration award in the district where the underlying contract was performed.
Cortez Byrd Chips, Inc. v. Bill Harbert Construction Co. · filed 2000-03-28(a)(2)
The precise issue raised in the District Court was whether venue for Cortez Byrd’s motion under §§ 10 and 11 was properly laid in the southern district of Mississippi, within which the contract was performed. It was dearly proper under the general venue statute, which provides, among other things, for venue in a diversity action in “a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated.” 28 U. S. C. § 1391(a)(2).Read the full opinion on CourtListener →
Filing restrictions in other districts
Section 1391’s venue analysis does not change because a plaintiff must prepay filing fees to sue in other districts.
Akers v. Siereveld · filed 2022-03-22
To the extent he cannot file a case in the Seventh Circuit or other states without prepaying filing fees, that does not change the analysis under 28 U.S.C. § 1391 (governing venue).Read the full opinion on CourtListener →
Plaintiff convenience does not establish venue
Section 1391(b) does not make venue proper in a district merely because the plaintiff is located there when filing.
Wright v. Wilson · filed 2024-12-31(b)
Plaintiff has therefore failed to show that venue is proper in this District or that the Court erred by finding that venue would be proper in the Western District of Missouri.Read the full opinion on CourtListener →
Section 1391(b) does not permit venue based on the plaintiffs’ convenience when none of its statutory grounds applies.
Florestal v. Henry · filed 2022-11-18(b)
Plaintiffs’ convenience does not override the statutory mandate of § 1391(b).Read the full opinion on CourtListener →
Effect of arbitration agreement on venue
Section 1391 does not make venue improper merely because the parties agreed to arbitrate their dispute elsewhere.
ZAKRIE v. LISEC AMERICA, INC. · filed 2022-11-18
Thus, while it is undisputed that LiSec and UPG agreed to resolve this dispute in another forum (arbitration), this fact does not establish that venue is otherwise “wrong” or “improper” under 28 U.S.C. § 1391.Read the full opinion on CourtListener →
Section 1391 does not permit dismissal for improper venue based solely on an arbitration clause when no failure to satisfy its venue categories is asserted.
Diversified Maintenance Systems, Inc. v. J. Star Enterprises, Inc. · filed 2022-12-06
However, because Defendant does not argue that Plaintiff’s claims should be dismissed for failure to satisfy any of the categories ... listed in 28 U.S.C. § 1391, Plaintiff’s claims cannot be dismissed for improper venue.Read the full opinion on CourtListener →
Section 1391(b) governs whether venue is improper; enforcing an arbitration clause requires a motion to compel arbitration.
Faes & Company (London) Limited v. Blockware Solutions, LLC · filed 2023-05-31(b)
A motion to dismiss for improper venue suggests that venue is “wrong” or “improper,” as outlined by 28 U.S.C. § 1391. Atl. Marine Constr. Co., Inc. v. U.S. Dist. Ct. for W. Dist. of Texas, 571 U.S. 49, 56 (2013). “When venue is challenged, the court must determine whether the case falls within one of the three categories set out in § 1391(b).” Id. “Venue” should not, however, be confused with “forum.” A party seeking to enforce a forum selection clause—which an arbitration agreement falls under—must employ a different procedural mechanism.Read the full opinion on CourtListener →
Venue for habeas petitions
Section 1391(b) supports venue for a habeas petition in the division containing the county of conviction.
(HC) Pech v. Lemon · filed 2023-08-29(b)
In this case, Petitioner is challenging his conviction from San Joaquin County, which is in the Sacramento Division of the Eastern District of California. Venue is therefore proper in the Sacramento Division, and the petition should have been filed there.Read the full opinion on CourtListener →
Under § 1391(b), venue for a challenge to a conviction lies in the district containing the county of conviction.
(HC) Alvarez v. Cates · filed 2021-10-26(b)
In this case, the petitioner is challenging a conviction from Los Angeles County, which is in the Central District of California. Therefore, the petition should have been filed in the United States District Court for the Central District of California.Read the full opinion on CourtListener →
Foreign defendants
Section 1391(c)(3) requires a court to disregard a defendant who does not reside in the United States when determining where an action may be brought against other defendants.
Lai v. Lu · filed 2025-06-05(c)(3)
Thus, the Court does not consider Ms. Zhang’s residence in ruling on Ms. Lu’s motion.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who does not reside in the United States to be sued in any judicial district; invoking that rule requires an allegation that the defendant resides outside the United States.
Brown v. Does 1-20 · filed 2025-05-19(c)(3)
In the event no defendant resides in a district within the United States, Section 1391(c) controls. ... That section provides that “a defendant not resident in the United States may be sued in any judicial district.” 28 U.S.C. § 1391(c)(3). ... Mr. Brown does not allege that defendants do not reside in the United States. Nor do any of his allegations suggest that they or their agents reside in this District. Absent any allegation regarding defendants’ location, there is not a colorable basis for venue in this District.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who is not resident in the United States to be sued in any judicial district.
Peanuts Worldwide LLC v. The Partnerships and Unincorporated Associations Identified on Schedule A · filed 2024-06-25(c)(3)
Defendant’s challenge to venue is a nonstarter: as a nonresident of the United States, it has no rights under the venue laws.Read the full opinion on CourtListener →
Section 1391 permits a defendant that does not reside in the United States to be sued in any judicial district.
Laborers District Council Construction Industry Pension Fund v. Sea Limited · filed 2024-05-31(c)(3)
Under 28 U.S.C. § 1391, a defendant that is not a resident in the United States—like Sea—may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a foreign defendant to be sued in any judicial district and disregards its joinder when determining venue for other defendants.
Mayborn (UK) Limited v. Comotomo Inc. · filed 2023-01-03(c)(3)
Section 1400(b) does not apply to foreign defendants, however, which “may be sued in any judicial district.” 28 U.S.C. § 1391(c)(3). “[T]he joinder of such a defendant shall be disregarded in determining where the action may be brought with respect to other defendants.” Id.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who is not resident in the United States to be sued in any judicial district.
Levi Strauss & Co. v. Connolly · filed 2023-03-02(c)(3)
Even if there was no waiver, there is no dispute that Mr. Connolly resides in Australia. He therefore may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c)(3) makes venue proper in any judicial district for a foreign defendant.
SVV Technology Innovations, Inc. v. ASUSTeK Computer Inc. · filed 2023-04-03(c)(3)
As a foreign defendant, venue is proper in the NDCA under 28 U.S.C. § 1391(c)(3).Read the full opinion on CourtListener →
Section 1391(c)(3) makes venue proper in any judicial district for a foreign defendant.
SVV Technology Innovations Inc. v. Acer Inc. · filed 2023-04-03(c)(3)
As a foreign defendant, venue is proper in the NDCA under 28 U.S.C. § 1391(c)(3).Read the full opinion on CourtListener →
Section 1391(c)(3) permits a foreign defendant to be sued in any judicial district.
SVV Technology Innovations, Inc. v. Micro-Star International Co. Ltd. · filed 2023-04-04(c)(3)
As a foreign defendant, venue is proper in the CDCA under 28 U.S.C. § 1391(c)(3).Read the full opinion on CourtListener →
Section 1391 permits a defendant that does not reside in the United States to be sued in any federal judicial district.
SME Steel Contractors v. Dowco Consultants · filed 2023-03-30(b)(1), (c)(3)
Dowco is a Canadian company, so the case could have been brought in the Southern District of California. See 28 U.S.C. § 1391(b)(1), (c)(3).Read the full opinion on CourtListener →
Section 1391(c)(3) allows a defendant who does not reside in the United States to be sued in any judicial district.
Beijing Meishe Network Technology Co., Ltd. v. TikTok Inc. · filed 2023-04-11(c)(3)
Taking the venue steps in order, we begin with a determination of whether venue would be proper in the transferee district and find that it would. ... Defendants further contend that ... Defendants ByteDance, Ltd. and TikTok Pte. Ltd. are foreign corporations for whom venue is also proper in NDCA under 28 U.S.C. § 1391(c)(3). ... As such allegations were sufficient to hail those defendants into this court, they should be sufficient to hail those defendants into NDCA. Accordingly, this court determines Defendants have shown that this case could have been brought in NDCA.Read the full opinion on CourtListener →
A defendant who does not reside in the United States may be sued in any judicial district.
Twows, LLC v. The Individuals, Partnerships, and Unincorporated Associations Identified on Schedule A · filed 2023-04-07(c)(3)
Plaintiff has demonstrated a prima facie showing that venue is proper in this District because, for venue purposes, “a defendant not resident in the United States may be sued in any judicial district.”Read the full opinion on CourtListener →
Section 1391(c) permits a defendant who does not reside in the United States to be sued in any judicial district.
Google LLC v. Saeed · filed 2023-04-25(c)
Venue is proper in this judicial district under 28 U.S.C. § 1391(c) because Defendants are not residents of the United States and may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c)(3) allows a defendant who is not a United States resident to be sued in any judicial district.
Google LLC v. Saeed · filed 2023-05-05(c)(3)
Venue is proper in this judicial district under 28 U.S.C. § 1391(c) because Defendants are not residents of the United States and may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c) permits a defendant who is not a resident of the United States to be sued in any judicial district.
Google LLC v. Saeed · filed 2023-06-23(c)
Venue is proper in this judicial district under 28 U.S.C. § 1391(c) because Defendants are not residents of the United States and may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who does not reside in the United States to be sued in any judicial district.
Doe v. d'Espalungue d'Arros · filed 2023-06-27(c)(3)
Venue is proper because the assault occurred in the Western District of Louisiana, the Plaintiffs reside in Lafayette, Louisiana, and because the Defendant is a foreign national who may be sued in any judicial district.Read the full opinion on CourtListener →
A defendant outside the United States may be sued in any judicial district and is disregarded when determining venue for other defendants.
Gurudu-Group LLC v. RAM Robinsons Automation Machinery LLC · filed 2023-07-07(c)(3)
However, because Robinsons UK (the other remaining defendant) is a foreign entity, it may be sued in any judicial district and its residency is not considered for determining where venue may be proper. See 28 U.S.C § 1391(c)(3) (“[A] defendant not resident in the United States may be sued in any judicial district, and the joinder of such a defendant shall be disregarded in determining where the action may be brought with respect to other defendants.”). Thus, because Mino is a resident of the Eastern District of Michigan, venue there would be proper.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant that does not reside in the United States to be sued in any district and disregards that defendant’s joinder when determining venue for other defendants.
HERON THERAPEUTICS, INC. v. SLAYBACK PHARMA LLC · filed 2024-07-02(c)(3)
As concerns Slayback Pharma India LLP, venue is proper in the District of Delaware. That is because under § 1391(c)(3), “a defendant not resident in the United States may be sued in any district, and the joinder of such a defendant shall be disregarded in determining where the action may be brought with respect to other defendants.”Read the full opinion on CourtListener →
Section 1391(c)(3) permits suit against a foreign defendant in any judicial district that has personal jurisdiction over it.
SK nexilis Co., Ltd. v. Solus Advanced Materials Co., Ltd. · filed 2025-05-13(c)(3)
Foreign defendants str subject to suit in any judicial district that has personal jurisdiction over it.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who does not reside in the United States to be sued in any judicial district.
ANIMACCORD LTD. v. THE INDIVIDUALS, PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A · filed 2025-06-13(c)(3)
Plaintiff has demonstrated a prima facie showing that venue is proper in this District because, for venue purposes, “a defendant not resident in the United States may be sued in any judicial district.” 28 U.S.C. § 1391(c)(3).Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who is not a United States resident to be sued in any judicial district.
Google LLC v. Does 1-25 · filed 2025-07-01(c)(3)
Venue is proper in this judicial district under 28 U.S.C. § 1391(c)(3) because Defendants are not residents of the United States and may be sued in any judicial district.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a foreign defendant to be sued in any federal judicial district.
Vifor (International) AG v. Orbicular Pharmaceutical Technologies Pvt. Ltd. · filed 2025-08-22(c)(3)
Orbicular also argues that because Orbicular is a foreign company, venue for this case would have been proper in any district court. ... Accordingly, I conclude that the District of New Jersey would be a proper venue.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant who does not reside in the United States to be sued in any judicial district.
Changsha Suda Electronic Commerce LLC v. Guangzhou Yimei Cosmetics Co Ltd · filed 2025-10-29(c)(3)
As relevant here, “a defendant not resident in the United States may be sued in any judicial district.” 28 U.S.C. § 1391(c)(3). Accordingly, venue is appropriate here.Read the full opinion on CourtListener →
Section 1391 treats a foreign defendant as a resident of any judicial district for venue purposes.
Knossos Global Systems LLC v. Zoho Corporation Private Limited · filed 2026-03-26(c)(3)
Defendant is a foreign company and is therefore a resident of “any judicial district” under 28 U.S.C. § 1391.Read the full opinion on CourtListener →
Section 1391 permits a foreign defendant to be sued in any judicial district.
Electraled, Inc. v. LMPG Inc. · filed 2026-03-31(c)(3)
Defendant is a foreign company and is therefore a resident of “any judicial district” under 28 U.S.C. § 1391. A patent infringement suit “may be brought in the judicial district where the defendant resides.” 28 U.S.C. § 1400. Therefore, venue is proper in either the Eastern District of Texas or the District of Massachusetts.Read the full opinion on CourtListener →
Section 1391(c)(3) permits a defendant that is not resident in the United States to be sued in any judicial district.
GENENTECH, INC. v. SANDOZ, INC. · filed 2024-03-05(c)(3)
Sandoz is considered to reside in Delaware because it was incorporated there (ECF No. 47-25 (Def. Br.) at 15; see T.C. Heartland LLC v. Kraft Foods Grp. Brands LLC, 581 U.S. 258, 261-62 (2017)), and Lek is a foreign corporation that may be sued in any judicial district.Read the full opinion on CourtListener →
Application to ATS and TVPA actions
Section 1391 governs venue in ATS and TVPA actions because those statutes contain no venue provisions.
Sikhs for Justice v. Mann · filed 2023-04-10
Neither the ATS nor the TVPA contain a venue provision. ... Therefore, the general venue statute, 28 U.S.C. § 1391, applies.Read the full opinion on CourtListener →
Private right of action
Section 1391 governs venue and does not provide a private right of action.
Gomez v. City of Sioux Falls · filed 2023-04-12
28 U.S.C. § 1391 is a provision governing venue, and Gomez provides no explanation as to how this statute would provide a private right of action.Read the full opinion on CourtListener →
Transactional venue
Transactional venue based on a rule’s burdens requires a named plaintiff who is present in the district and bears those burdens; effects on nonparties do not suffice.
Career Colleges & Schools of Texas v. United States Department of Education · filed 2023-04-17(e)(1)(B)
The plain text “events or omissions giving rise to the claim” implicates “the” parties bringing the claim and not “a” generalized burden on non- parties.Read the full opinion on CourtListener →
Unidentified defendants
Section 1391(b)(1) does not establish improper venue based on defendants’ residences when an unidentified defendant might reside in the district.
Konitzer v. Kuber · filed 2023-11-09(b)(1)
However, because the Jane Doe defendant has not yet been identified, the court cannot conclude with certainty that none of the defendants resided within this district at the time this lawsuit was filed.Read the full opinion on CourtListener →
Section 1391(b) does not permit a definitive finding that venue is improper based on defendants’ residences when an unidentified defendant may reside in the district.
Konitzer, Scott v. Dept. of Corrections Medical Director · filed 2023-11-09(b)
Absent authority from the state defendants suggesting that this court can conclude that venue is improper when the residences of yet-to-be identified defendants are unknown, the court cannot definitively find improper venue, although it seems more probable than not given that the Jane Doe defendant, too, worked at the Racine Correctional Institution.Read the full opinion on CourtListener →
Venue for § 1981 and state law claims
Section 1391 governs venue for § 1981 and state law defamation claims, and plaintiffs must establish a proper venue for those claims.
Martin v. Impact Health · filed 2023-11-13
Given Plaintiffs’ failure to offer anything more than a conclusory statement that their “claims are in the proper district,”31 and the burden imposed on them in response to a Rule 12(b)(3) motion, Plaintiffs have not carried their burden to establish that venue is proper in this district under either §2000e-5(f)(3) or § 1391.Read the full opinion on CourtListener →
Section 1391(b) governs venue for Section 1981 claims and permits suit in a district where a substantial part of the events giving rise to the claim occurred.
Samuels v. Small Business Administration · filed 2024-05-30(b)
He does not, however, provide any facts suggesting that anything related to his pleading occurred in this district. Under the general venue provision, 28 U.S.C. § 1391, which applies to Section 1981 claims, such claims may be brought in: (1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located; (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated; or (3) if there is no district in which an action may otherwise be brought as provided in this 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).Read the full opinion on CourtListener →
Section 1391(b) permits venue for a state law employment discrimination claim where the defendant resides or a substantial part of the events giving rise to the claim occurred.
Jeschke v. Five Below, Inc. · filed 2024-11-27(b)(1), (b)(2)
Venue for Plaintiff’s NYSHRL claim under Section 1391(b)(1) and (b)(2) is therefore proper in the Northern District of New York.Read the full opinion on CourtListener →
Section 1391 governs venue for Section 1981 claims and permits suit in a district where a substantial part of the events giving rise to the claim occurred.
Dowell v. Quontic Bank · filed 2025-05-14(b)
By contrast, claims brought under Section 1981 are governed by the general venue statute, 28 U.S.C. § 1391. ... Because venue is proper in the Eastern District of New York, both for Plaintiff’s Section 1981 claim and her Title VII claim, the Court concludes that transfer to the Eastern District of New York, where both claims can be heard, is in the interest of justice.Read the full opinion on CourtListener →
Alternative bases for venue
Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.
Burchette v. Millan · filed 2024-06-26(b)(1), (b)(2)
Because she alleges that Defendant is located in Hillsborough County, where the events giving rise to her claims is occurring, from the face of the complaint, it is clear that venue is not proper in this court under Section 1391(b)(1), (2).Read the full opinion on CourtListener →
Section 1391(b)(1) and (2) permit venue where the defendant resides or a substantial part of the events giving rise to the claim occurred.
Federal Insurance Company v. Shaw Industries Inc · filed 2024-06-07(b)(1)-(2)
A review of the record shows quite clearly that this matter could have originally been filed in the Northern District of Georgia under both § 1391(b)(1) and (2).Read the full opinion on CourtListener →
Section 1391(b)(1) and (d) can provide a proper venue after certain defendants are dismissed.
Anderson v. Amazon.com, Inc. · filed 2024-05-31(b)(1), (d)
But because the Individual Defendants have been dismissed, venue is proper in this district under 28 U.S.C. § 1391(b)(1), (d).Read the full opinion on CourtListener →
Section 1391(b) permits venue where a defendant resides if all defendants reside in the same state, or where a substantial part of the events giving rise to the claim occurred.
Hancock v. Centurion Health · filed 2024-05-28(b)(1)–(2)
Because all defendants to the current action are alleged to reside in Tennessee, venue is proper in any district where one of them resides or where a substantial part of the events giving rise to the action occurred. 28 U.S.C. § 1391(b)(1)–(2).Read the full opinion on CourtListener →
Section 1391(b) does not establish venue in a district when the complaint alleges neither qualifying defendant residence nor a substantial part of the events there.
Presidential Candidate Number P60005535 v. Biden · filed 2024-05-29(b)
The Magistrate Judge determined that Defendants do not reside in South Carolina, nor did a substantial part of the alleged acts or omissions giving rise to the claim occur in South Carolina. Upon review for clear error, the Court finds that, as explained in more detail by the Magistrate Judge, Plaintiff has not provided any allegations that would support a finding that venue is proper in the United States District Court for the District of South Carolina.Read the full opinion on CourtListener →
Section 1391(b) does not permit venue in a district where no defendant resides and none of the events giving rise to the claims occurred.
Gonsalves v. CA · filed 2024-06-03(b)
Because none of the events or omissions giving rise to Plaintiff's claims are alleged to have occurred in either San Diego or Imperial County and because no Defendant resides here, the Court finds venue is not proper in the Southern District.Read the full opinion on CourtListener →
Section 1391(b)(1) permits venue where a defendant resides if all defendants reside in that state, and (b)(2) permits venue where a substantial part of the events giving rise to the claim occurred.
Bradbury v. City of Montpelier, VT · filed 2024-05-21(b)(1), (b)(2)
Because Defendants reside in Vermont and the alleged events giving rise to his claims occurred in Vermont, from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).Read the full opinion on CourtListener →
Section 1391(b)(1) and (2) do not permit venue in a district where the defendant does not reside and no substantial part of the events giving rise to the claims occurred.
Dupree v. Behaviorally · filed 2024-05-21(b)(1), (b)(2)
Because Defendant Behaviorally does not reside in this district and the alleged events giving rise to Plaintiff’s claims occurred in either New Jersey, within the District of New Jersey, or in Queens County, New York, which is located within the United States District Court for the Eastern District of New York,3 venue for the FLSA and state law claims is not proper in this court under Section 1391(b)(1) or (2).Read the full opinion on CourtListener →
Section 1391(b) generally places venue where a defendant resides or a substantial part of the events occurred.
Perron v. The City of Manhattan, New York · filed 2024-05-21(b)
Fourth, the Central District of California is an improper venue. ... However, the Court would note that Perron’s Complaint clearly rests upon allegations of actions and events that occurred in solely New York by New York Defendants. Wenue, therefore, does not lay in the Central District of California.Read the full opinion on CourtListener →
Section 1391(b)(1) permits venue based on defendants’ residence, but failing to satisfy it alone does not make venue improper.
Kapitus Servicing, Inc v. Verma · filed 2023-12-19(b)(1)
However, merely failing to satisfy § 1391(b)(1) does not render venue improper, as it is not the only subsection of that statutory provision.Read the full opinion on CourtListener →
Section 1391(b) permits venue based on defendants’ residence, where a substantial part of the events occurred, or, when neither basis provides a district, where a defendant is subject to personal jurisdiction.
Pariti v. McGowan · filed 2024-03-04(b)
Once again, the Complaint alleges that all Defendants reside in New York, and Plaintiffs seek redress for alleged events that occurred in New York. (Doc. # 1). Therefore, although Plaintiffs allege that they were instructed to file this suit in the Northern District of Alabama, this court is simply not a proper venue for Plaintiffs’ claims.Read the full opinion on CourtListener →
Section 1391 permits venue where a defendant entity resides through personal jurisdiction or where a substantial part of the events giving rise to the claim occurred.
Savista, LLC v. GS Labs, LLC · filed 2024-03-11(b)(1), (b)(2), (c)(2)
Because the Court has personal jurisdiction over GS Labs and because events underlying the lawsuit occurred in this district, the Court finds that venue is proper here. See 28 U.S.C. §§ 1391(b)(1)–2, 1391(c)(2).Read the full opinion on CourtListener →
Section 1391(b) permits venue where the defendant resides or where a substantial part of the events giving rise to the claim occurred.
Steele v. Boston Mutual Insurance Company · filed 2024-03-11(b)(1), (b)(2)
Therefore, it appears that venue under both Sections 1391(b)(1) and 1391(b)(2) is proper in the District of Massachusetts.Read the full opinion on CourtListener →
Section 1391(b) permits venue where a defendant resides or where a substantial part of the events giving rise to the claim occurred.
Woodard v. Saint Charles County MO · filed 2025-09-22(b)
The United States District Court for the Western District of Missouri is not a proper venue as the Defendant does not reside in the Western District of Missouri nor did a substantial part of the events or omissions giving rise to the claim occurred in the Western District of Missouri.Read the full opinion on CourtListener →
Section 1391(b)(1) and (2) do not permit venue in a district where no defendant is shown to reside and the events giving rise to the claims occurred elsewhere.
Haley · filed 2025-11-18(b)(1), (2)
Because Defendants are employed by Monroe County and the alleged events occurred in Monroe County, from the face of the complaint, it is clear that venue is not proper in this Court under Section 1391(b)(1), (2).Read the full opinion on CourtListener →
Applicability to FOIA actions
Section 1391’s general venue rules do not apply to FOIA actions.
Abissi v. United States Citizenship and Immigration Services · filed 2024-04-05
The general federal venue provision, 28 U.S.C. § 1391, does not apply to FOIA actions.Read the full opinion on CourtListener →
Where a state resides for venue purposes
Section 1391(c)(2)’s residency rule for entities does not apply to states; a state resides in every district within its borders.
The Daily Wire, LLC v. United States Department of State · filed 2024-05-07(c)(2)
The term “entity” is undefined in the statute but commonly means “[a]n organization (such as a business or a governmental unit) that has a legal identity apart from its members,” not a state.Read the full opinion on CourtListener →
Section 1391(b)(1) permits venue in a district where a defendant resides if all defendants reside in the same state.
Shih v. Bankers Healthcare Group, LLC · filed 2024-06-27(b)(1)
Even if the Court did assume that venue was proper in this district, because Defendant is located in Syracuse, Onondaga County, New York, which falls within the Northern District of New York, venue is proper in the Northern District of New York under Section 1391(b)(1).Read the full opinion on CourtListener →
Section 1391(e)(1) permits an action against federal agencies or officials to be brought in the district where the plaintiff resides.
Patel v. Secretary, U.S. Department of Homeland Security · filed 2024-11-15(e)(1)
The Court agrees with Defendants that this case could have been brought in the Middle ... District of Florida because Patel resides there. See ECF 1 at 1 (listing Patel’s address in Jacksonville, Florida); 28 U.S.C. § 1391(e)(1) (providing that, in actions naming federal agencies or officials as defendants, venue is proper, inter alia, in the district where the plaintiff resides).Read the full opinion on CourtListener →
Section 1391(b)(1) permits venue where the defendant resides, including the district of a corporate defendant’s principal place of business.
In re: Bon Secours Mercy Health Data Breach Litig. · filed 2025-07-02(b)(1)
Moreover, venue is proper because Bon Secours resides here—its principal place of business is in Cincinnati, Ohio. 28 U.S.C. § 1391(b)(1).Read the full opinion on CourtListener →
Section 1391(b) permits venue where the defendant resides or where a substantial part of the events occurred.
Negron v. Ascension Health · filed 2025-09-23(b)
Venue is a separate inquiry and is proper in the district where the defendant resides or where a substantial part of events occurred. 28 U.S.C. § 1391(b). ... This Court has no trouble accepting that venue is proper in Missouri, where Ascension is domiciled and perhaps certain systemwide decisions were made, and that Florida subclass claims arose in Florida, where Florida Ascension patients received HIPAA Notices, provided their PII/PHI, and suffered losses from the breach.Read the full opinion on CourtListener →
Section 1391(b)(1) permits venue where the defendant resides; the court found venue proper in Missouri because Cioni resides there.
Ketner · filed 2026-03-09(b)(1)
Similarly, venue is proper in Missouri because Cioni resides there and is subject to personal jurisdiction there. See 28 U.S.C. § 1391(b)(1).Read the full opinion on CourtListener →
Section 1391(b)(1) permits a trademark infringement action in a district where the defendant resides when all defendants reside in that district’s state.
Opulent Treasures, Inc. v. Ya Ya Creations, Inc. · filed 2022-03-30(b)(1)
As a preliminary matter, YYC asserts—and Opulent does not contest—that this case could have originally been filed in the CDCA because YYC is incorporated and headquartered in the CDCA and a trademark owner may file an infringement action in “a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located.” 28 U.S.C. § 1391(b). Accordingly, the Court analyzes the private and public interest factors to determine whether YYC has met its burden of showing that the CDCA is clearly more convenient than the EDTX in this case.Read the full opinion on CourtListener →
Venue for multiple plaintiffs
Section 1391(b)(2) permits venue where a substantial part of the relevant events or omissions occurred, without requiring each plaintiff to establish venue separately.
Beyard v. Pentagon Federal Credit Union · filed 2025-02-06(b)(2)
At the end of the day, 28 U.S.C. § 1391 requires only that “a substantial part” of the relevant “events or omissions” occurred within this District—without imposing any plaintiff-by-plaintiff requirements.Read the full opinion on CourtListener →
Judicial bias and venue
Section 1391(b) sets the requirements for proper venue; judicial bias is not one of them.
Kelly · filed 2025-12-01(b)
As previously stated, Section 1391 explicitly spells out the requirements for proper venue, none of which involve judicial bias.Read the full opinion on CourtListener →
Venue for delayed Social Security applications
Section 1391(b) governs venue for an action seeking to compel the Social Security Administration to act on a pending benefits application rather than review a final decision.
Amari J. Moody v. Kijakazi · filed 2026-01-08(b)
The general venue statute therefore applies to this action. ... It appears from the allegations of the complaint that Plaintiff’s application is pending in Dacula, which is located in Gwinnett County, Georgia. Gwinnett County is in the Northern District of Georgia, 28 U.S.C. § 90(a)(2), and it is reasonable to expect that all relevant documents will be in that district. Transfer to the United States District Court for the Northern District of Georgia therefore appears to be appropriate in this case.Read the full opinion on CourtListener →
Location of a party’s attorney
Section 1391(b) does not make the location of a party’s attorney a basis for venue.
Hooli v. Mitcham · filed 2026-01-27(b)
In any event, appellant’s contention that venue was proper because counsel for Mitcham has an office in the District of Columbia is erroneous because the location of a party’s attorney is not a valid basis for venue. See 28 U.S.C. § 1391(b).Read the full opinion on CourtListener →
Exceptions to the general venue rule
Law changed since Pub. L. 112-63 (Jan. 6, 2012) rewrote the general venue rules and removed the former § 1392(a) provision for defendants in different districts of one state.
Section 1391(b) allows venue in a district authorized by another law, even when its general venue rule would place the action elsewhere.
Quinn v. State of Mo. · filed 1988-03-15(b)
Title 28 U.S.C. § 1391(b) states that “[a] civil action wherein jurisdiction is not founded solely on diversity of citizenship may be brought only in the judicial district where all defendants reside, or in which the claim arose, except as otherwise provided by law.” However, in civil actions not of a local nature where, as here, all defendants reside within the state but in different districts, § 1392(a) permits venue in any district where one or more defendants reside. This provision is satisfied where plaintiffs challenge the constitutionality of a state constitutional provision and defendant John Ashcroft, the Governor, and defendant Morgan, a board member, reside in the Western District of Missouri.Read the full opinion on CourtListener →
Law changed since Same change as noted above.
Section 1391(b)'s general venue rule is subject to § 1392(a) when defendants reside in different districts of the same state.
Khalil-Ullah Al-Muhaymin v. Jones · filed 1990-02-15(b)
Although the language of section 1391(b) would appear to be applicable, it must be read in conjunction with section 1392(a), which provides an exception when there are multiple defendants residing within the same state but in different districts.Read the full opinion on CourtListener →
Notes 8551–8639 of 8,639, oldest cases first.
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