Williams v. Baldolf

Benita Williams (plaintiff) was a prisoner held at a halfway house in Youngstown, Ohio, which was located in the Northern District of Ohio. Williams sued Baldolf and others (defendants) in federal court in the Southern District of Ohio, alleging she was not allowed to leave the halfway house even though her prison sentence had ended. Two of the three defendants resided in the Southern District of Ohio. Williams also had a different case proceeding in the Southern District of Ohio. Without providing an opportunity for the parties to be heard, a magistrate judge in the Southern District of Ohio transferred the case to the United States District Court for the Northern District of Ohio, Eastern Division at Youngstown. The transfer order stated that under 28 U.S.C. § 1404(a), a civil action could be transferred for the convenience of the parties and witnesses to any other forum where the action could have originally been brought. The order did not discuss any public- or private-interest factors supporting the transfer and did not discuss Williams’s choice to file in the Southern District of Ohio. The order stated that the action could have been brought in the Northern District of Ohio because the halfway house was in that district. Nothing in the order or the accompanying documents indicated Williams’s reasons for filing suit in the Southern District of Ohio.