Joffe v. U.S. Department of Homeland Security and Immigration and Customs…
Steven L. Joffe, M.D. v. U.S. Department of Homeland Security and Immigration and Customs Enforcement
- Katherine Menendez
- 0:26-cv-00986
- U.S. District Court · District of Minnesota
- 1
Counsel of record per CourtListener. Firm names are approximate.
In Joffe v. U.S. Department of Homeland Security and Immigration and Customs Enforcement, Judge Menendez denied Dr. Steven L. Joffe's request to transfer the case to a different court because the case had already been dismissed and there was nothing left to transfer.
Dr. Steven L. Joffe, the plaintiff, who sought to transfer a dismissed case to a different federal court. The ruling leaves him free to refile in another district but does not transfer the existing (dismissed) action.
What happened
In Joffe v. U.S. Department of Homeland Security and Immigration and Customs Enforcement (Case No. 26-cv-986), Dr. Steven L. Joffe filed a lawsuit against the U.S. Department of Homeland Security and Immigration and Customs Enforcement in the District of Minnesota. After the court dismissed the case, Dr. Joffe asked the court to move it to the federal court for the District of Columbia instead.
The court explained that once a case has been dismissed and a final judgment entered, there is no longer an active case to transfer to another court. The motion to change the location of the case was therefore denied. The court also noted that simply filing the case in a different district would not, on its own, fix the legal problem — described as a jurisdictional issue — that led to the dismissal in the first place.
Judge Katherine M. Menendez issued this ruling on March 31, 2026. Because the earlier dismissal was "without prejudice" — meaning it did not permanently bar Dr. Joffe from trying again — the court noted that he is free to file a new case in a different district court if he chooses, though any jurisdictional problems identified in the dismissal order would still need to be addressed.
The detailed version
- Joffe v. U.S. Department of Homeland Security and Immigration and Customs… · No. 0:26-cv-00986
- Katherine Menendez
- Mar. 31, 2026
Background
Dr. Steven L. Joffe filed suit in the U.S. District Court for the District of Minnesota against the U.S. Department of Homeland Security and Immigration and Customs Enforcement. Prior to this order, the court had already issued an Order of Dismissal (Dkt. 10) and entered judgment, dismissing the case without prejudice. The nature of the underlying claims is not described in this order.
The Motion
After the case was dismissed, Dr. Joffe filed a Motion for a Change of Venue (Dkt. 12), seeking to transfer the action to the U.S. District Court for the District of Columbia.
The Court's Ruling
Judge Menendez denied the motion. The court's reasoning was straightforward: once a case has been dismissed and judgment entered, there is no longer a live case that can be transferred to another district. The court cited Lasher v. Stavis, No. 17-cv-6632 (JPO), 2018 WL 6521586, at *3 (S.D.N.Y. Dec. 12, 2018), for the proposition that a motion to change venue filed after dismissal must be denied because "there is no case to transfer."
Jurisdictional Note and Effect of Dismissal
The court observed that transferring the case to a different district would not, by itself, cure the jurisdictional defect identified in the prior Order of Dismissal. Jurisdiction refers to a court's legal authority to hear a particular case; if that authority was lacking in Minnesota, it may still be lacking elsewhere unless additional facts or legal arguments address the problem.
However, because the dismissal was entered "without prejudice," Dr. Joffe retains the right to file a new, separate lawsuit in another district court if he chooses. A dismissal without prejudice does not permanently bar a plaintiff from refiling; it simply ends the current case without deciding its merits.
Reviewer note from the AI+
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.