A geographic subdivision of a state for purposes of the federal judicial system. The division determines where a defendant resides for venue purposes and where a civil action may be brought under the general venue statute.
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How its tested
Common Examples
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Corporate Residence Supports Venue
Jorge Juarez sued Jenkins Apparel in the Northern District of State E after a contract dispute. Jenkins Apparel is incorporated in State E and maintains its principal offices and multiple stores in the Northern District. Because the sole defendant resides in the Northern District and all defendants reside in State E, venue is proper there.
Extended Response Time Outside District
Jordan Jenkins mailed a waiver request to Jamal Jefferson who lived in a foreign country. Jefferson received the request but failed to return it. Because the request was sent outside any judicial district of the United States, Jefferson had ninety days to respond before default proceedings could begin.
Federal agents obtained a summons against Jefferson Trust for a criminal violation. The organization maintained its headquarters abroad. The summons could be served at the foreign location because the rule permits service outside any judicial district of the United States when authorized by statute.
Fallback Venue Based on Jurisdiction
Jacob Jennings sued Jaffe Securities after a securities transaction collapsed. No district satisfied the residence or events tests because the company had no U.S. presence. The court permitted suit in the district where Jaffe Securities was subject to personal jurisdiction under the fallback provision.
Entity Residence Determined by Contacts
Jerome Jackson filed suit against Jordan Dynamics in the Western District of State A. Jordan Dynamics is incorporated in State A and operates a data center in the Western District. The company is deemed to reside in the Western District because its contacts there support personal jurisdiction over the claim.
Filing Location Tied to Residence
Jacqueline Juarez challenged an agency decision denying benefits. She resided in the Eastern District of her state at the time of filing. The statute directed her to commence the action in the judicial district where she resided or maintained her principal place of business.
Matthews v. Eldridge424 U.S. 319 (1976)
George Eldridge was first awarded Social Security disability benefits in June 1968. In March 1972 he received a questionnaire from the state agency charged with monitoring his medical condition. He completed and returned the questionnaire, indicating that his condition had not improved and identifying recent medical sources. The state agency obtained reports from his physician and a psychiatric consultant.
After reviewing those reports and other information in his file, the agency sent Eldridge a letter stating that it had made a tentative determination that his disability had ceased in May 1972. The letter included a statement of reasons for the proposed termination and advised Eldridge that he could request time to submit additional information. Eldridge responded in writing, disputing one characterization of his medical condition and asserting that the agency already possessed sufficient evidence of his disability.
The state agency then made a final determination that Eldridge had ceased to be disabled in May 1972; the Social Security Administration accepted that determination. In July 1972 Eldridge received written notice that his benefits would terminate after that month and that he could seek reconsideration by the state agency within six months.
Instead of requesting reconsideration, Eldridge filed suit in the United States District Court for the Western District of Virginia. He challenged the constitutionality of the Secretary's termination procedures and sought an injunction barring termination of benefits until a pretermination evidentiary hearing was provided, together with immediate reinstatement of benefits. The District Court held that the existing procedures violated the Fifth Amendment's Due Process Clause, ordered the Secretary to provide Eldridge a pretermination hearing, and directed reinstatement of benefits pending that hearing. The Court of Appeals for the Fourth Circuit affirmed. The Supreme Court noted probable jurisdiction and heard the case.
How does a corporation determine its residence for venue purposes in a state with multiple judicial districts?
A corporation resides in any judicial district where its contacts would support personal jurisdiction if that district were treated as a separate state. When contacts are sufficient in more than one district, venue is proper in each of them provided all defendants reside in the same state.
Supporting sources
What happens when no district satisfies the residence or substantial-events tests?
The fallback provision allows venue in any judicial district where any defendant is subject to personal jurisdiction. This rule applies only after the court determines that neither the residence nor the events provisions can be satisfied.
Supporting sources
Does a natural person reside in the district of temporary presence or only in the district of domicile?
A natural person resides only in the judicial district of domicile. Temporary presence without intent to remain indefinitely does not establish residence for venue purposes even if the person performs work in the district.
Supporting sources
209 U.S. 123 (1908)
…Northern Pacific Railway Company, Defendant, heretofore instituted by him in the District Court of the County of Ramsey, Second Judicial District, State of Minnesota. Ordered further, that for his said contempt said Edward T. Young be fined the sum of one hundred dollars and stand committed in the custody of the Marshal of this…