Coltrane v. Lappin
United States District Court for the District of Columbia
885 F.Supp.2d 228 (2012)
Mary Coltrane's (plaintiff) son was imprisoned in a Louisiana federal prison, where he was murdered by fellow inmates. As a resident of Washington, D.C., (the District) Coltrane filed a pro se suit for damages in the United States District Court for the District of Columbia. Coltrane accused Harley Lappin and other prison officials and employees (defendants), most of whom lived in Louisiana, of actions that contributed to her son's death, as well as conspiracy to conceal those actions. Coltrane's suit combined two constitutional claims with one claim under the Federal Tort Claims Act (FTCA). Coltrane's residency in the District made either the District or Louisiana proper venues for her FTCA claim. However, because Coltrane lodged her constitutional claims against Lappin and the others in their individual rather than official capacities, Louisiana was the only proper venue for those claims. Because Coltrane improperly venued her constitutional claims in the District, Lappin and the other defendants moved to dismiss the suit or transfer it to the United States District Court for the Western District of Louisiana.
Rule of Law
Holding and Reasoning (Walton, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 726,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 726,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,700 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.