Coltrane v. Lappin
United States District Court for the District of Columbia
885 F.Supp.2d 228 (2012)
Relevant factsFree
Mary Coltrane (plaintiff), a pro se D.C. resident, sued prison officials (defendants), mostly Louisiana residents, over her son's murder in a Louisiana federal prison, combining two individual-capacity constitutional claims properly venued only in Louisiana with an FTCA claim properly venued in either D.C. or Louisiana; the defendants moved to dismiss or transfer the improperly venued constitutional claims to the Western District of Louisiana.
IssueFree
Whether, under the pendent-venue doctrine, a federal court may adjudicate a claim for which the court is an improper venue, if that claim is joined with another claim for which the court is a proper venue.
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