Coltrane v. Lappin

885 F.Supp.2d 228 (2012)

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Coltrane v. Lappin

United States District Court for the District of Columbia
885 F.Supp.2d 228 (2012)

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Facts

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

Issue

Holding and Reasoning (Walton, J.)

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