## Facts

- Mary L. Coltrane, proceeding pro se as administratrix of her son’s estate, sued federal Bureau of Prisons (BOP) officials and USP Pollock staff after inmate Carlton Coltrane was stabbed and killed at USP Pollock in Louisiana on January 18, 2010.
- The amended complaint alleged Carlton Coltrane repeatedly warned prison staff (verbally and in writing) about threats from other inmates and requested separation, but staff failed to act consistent with BOP policies.
- Plaintiff alleged defendants later engaged in a cover-up or conspiracy concerning the facts of the murder.
- Plaintiff filed suit in the District of Columbia and later filed a first amended complaint asserting constitutional claims against federal officials and a tort claim under the FTCA.
- Defendants moved to dismiss or, alternatively, to transfer the case to the Western District of Louisiana, where the prison, most defendants, key witnesses, and institutional records were located.

## Issues

1. Whether venue in the District of Columbia was proper under 28 U.S.C. § 1391 for claims arising from events at a federal prison in Louisiana.
2. Whether the action should be transferred to the Western District of Louisiana under 28 U.S.C. § 1404(a) for convenience and in the interest of justice.

## Decision

- The court granted defendants’ alternative motion to transfer and ordered transfer to the U.S. District Court for the Western District of Louisiana.
- The court did not decide the merits of the Fifth Amendment or FTCA theories, or defendants’ dismissal arguments, because transfer was warranted.
- The court found the locus of operative facts was Louisiana because the alleged failures to protect, related conduct, and the killing occurred at USP Pollock.
- The court concluded convenience favored Louisiana given the concentration of parties, witnesses (staff, medical personnel, and potential inmate witnesses), and records there.
- The court held the interest of justice favored litigating where the events occurred and where the local forum had a stronger connection to the dispute, and plaintiff’s D.C. residence did not outweigh those factors.

## Legal Principles

- Under 28 U.S.C. § 1404(a), a federal court may transfer a civil action to another district where it might have been brought when convenience of parties and witnesses and the interest of justice favor transfer.
- In assessing transfer, courts weigh the locus of operative facts, access to sources of proof, witness convenience and availability, and the forum’s connection to the controversy.
- A plaintiff’s choice of forum receives reduced weight when the chosen forum has minimal connection to the underlying events.

## Conclusion

The District of Columbia district court transferred the action to the Western District of Louisiana because the alleged conduct, witnesses, and evidence were centered at USP Pollock in Louisiana, making transfer appropriate under § 1404(a) despite the plaintiff’s selection of a District of Columbia forum.


Coltrane v. Lappin, 885 F. Supp. 2d 228 (D.D.C. 2012)