Sylvas v. Department of Corrections

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
DONALD SYLVAS CIVIL ACTION
VERSUS NO. 26-104
DEP’T. OF CORRECTIONS, ET AL. SECTION “B” (2)
ORDER AND REASONS
Plaintiff Donald Sylvas is incarcerated in the River Bend Detention Center (“RBDC”) in
Lake Providence, Louisiana. ECF No. 5, ¶II, at 3. Sylvas filed this pro se complaint under 42
U.S.C. § 1983 against defendants Department of Corrections, Instructor Johnson, David Faryox,
Toney Edwards, Wydette Williams, Wiley Jeremy, and Johnny Hedgemon, located in
Harrinsonburg and Lake Providence, Louisiana. Id. at 1, ¶III(B)-(G), at 5. Sylvas filed the
complaint challenging the terms of his confinement while in the custody of RBDC. Id. at 5-6.
Sylvas also submitted an application to proceed in forma pauperis in this case. ECF No. 6.
In light of the decision to transfer this matter, ruling on the pauper application is deferred to the
receiving court for consideration.
I. VENUE PROVISIONS
Because § 1983 contains no specific venue provision, venue is determined under the
general venue provisions of 28 U.S.C. § 1391.1 The general venue statute at 28 U.S.C. § 1391(b)
provides as follows:
A civil action 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
1 See Jones v. Bales, 58 F.R.D. 453 (N.D. Ga. 1972), aff’d, 480 F.2d 805 (5th Cir. 1973).
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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.
The provisions of 28 U.S.C. § 1404 and § 1406 allow a court to transfer a case from a
district in which venue is wrong to another district or division in which venue is proper, when
transfer is in the interest of justice.2 The transfer provisions “‘should be regarded as a federal
judicial housekeeping measure, dealing with the placement of litigation in the federal courts and
generally intended, on the basis of convenience and fairness, simply to authorize a change of
courtrooms.’”3 Some of the interests of justice to be weighed by a transferring court include “the
cost and ease of litigation,” “the interest in having a case involving local disputes and local law
resolved by a local court,” and the facilitation of judicial economy and avoidance of duplicitous
litigation.4 A court’s transfer inquiry requires an “individualized, case-by-case consideration of
convenience and fairness.”5
II. DISCUSSION
Sylvas has presented no basis for this matter to proceed in the Eastern District of Louisiana
rather than the Western District of Louisiana. The events complained about took place at RBDC
where Sylvas is currently housed in Lake Providence, Louisiana, which is located in East Carroll
Parish. ECF No. 5, ¶II, at 3. The named defendants are all located in East Carroll and Catahoula
Parishes. Id. at 1, ¶III(B)-(G), at 5. East Carroll and Catahoula Parishes falls within the
geographical boundaries of the United States District Court for the Western District of Louisiana.
2 See Balawajder v. Scott, 160 F.3d 1066 (5th Cir. 1998).
3 In re Rolls Royce Corp., 775 F.3d 671, 677 (5th Cir. 2014).
4 Id. at 677-78 (citing Atl. Marine Const. Co., Inc. v. U.S. Dist. Ct. W.D. Tex., 571 U.S. 49, 62 n.6 (2013)).
5 Id. at 678.
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28 U.S.C. § 98(c). The interests of justice and fairness to the parties dictate that venue is
appropriate in the Western District of Louisiana. Accordingly,
IT IS ORDERED that this case is TRANSFERRED to the United States District Court
for the Western District of Louisiana.
IT IS FURTHER ORDERED that determination of pauper status is DEFERRED to the
United States District Court for the Western District of Louisiana.
New Orleans, Louisiana, this _13th_ day of March, 2026.
_____________________________________
DONNA PHILLIPS CURRAULT
UNITED STATES MAGISTRATE JUDGE
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