Prisoners' Legal Services of New York v. U.S. Department of Homeland Security

CourtDistrict Court, W.D. New York
DecidedAugust 25, 2025
Docket1:25-cv-00787
StatusUnknown

This text of Prisoners' Legal Services of New York v. U.S. Department of Homeland Security (Prisoners' Legal Services of New York v. U.S. Department of Homeland Security) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Prisoners' Legal Services of New York v. U.S. Department of Homeland Security, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT ELECTRONICALLY FILED DOC #: _________________ SOUTHERN DISTRICT OF NEW YORK DATE FILED: 8/25/2025 ----------------------------------------------------------------- X : PRISONERS’ LEGAL SERVICES OF NEW : YORK, et al., : : 1:25-cv-1965-GHW Plaintiffs, : : MEMORANDUM OPINION & -v- : ORDER : UNITED STATES DEPARTMENT OF : HOMELAND SECUITY, et al., : Defendants. : ----------------------------------------------------------------- X GREGORY H. WOODS, United States District Judge: Plaintiffs Prisoners’ Legal Services of New York (“PLSNY”), the New York Civil Liberties Union (the “NYCLU”), and Robert F. Kennedy Human Rights (“RFKHR”) provide pro bono legal services to immigrants detained at the Buffalo Federal Detention Facility (“BFDF”). BFDF is an immigration-detention facility in Batavia, New York, in Genesee County, which lies in the Western District of New York. Around November 2024, Defendants expanded a “legal mail policy” at BFDF, under which United States Immigration and Customs Enforcement (“ICE”) officers working at that facility inspect, copy, and retain all legal documents sent to or from detainees. This policy applies categorically to all incoming and outgoing correspondence, with no exception for attorney-client communications. Plaintiffs filed this action in response, asserting that Defendants’ policy violates the Administrative Procedure Act (“APA”) and their First Amendment right to speak freely through privileged and confidential communications with their clients detained at BFDF. The threshold question is whether this action should be litigated in the Southern District of New York or the Western District of New York. All of the events underlying this case occurred at BFDF itself where the legal mail policy was developed, implemented, and enforced. And none of the events underlying this case occurred in the Southern District of New York. Because the only connection to this district is that two of the three Plaintiffs reside here and because Plaintiffs’ arguments against transfer ignore their APA claim entirely—Defendants’ motion to transfer this case to the Western District of New York is GRANTED. I. BACKGROUND A. Factual Background Plaintiffs are three “nonprofits who provide pro bono legal services” to individuals detained at

BFDF. Dkt. No. 1 (“Compl.”) ¶¶ 1, 8–10. PLSNY is incorporated in New York State and maintains offices in Buffalo, Newburgh, Ithaca, and Albany. Dkt. No. 23 (“Nowak Decl.”) ¶ 3. The NYCLU is also incorporated in New York State, with its headquarters in Manhattan at 125 Broad Street. Dkt. No. 24 (“Belsher Decl.”) ¶ 3. RFKHR is incorporated in Washington, D.C., and maintains two offices, one in D.C., and one in Manhattan, located at 88 Pine Street. Dkt. No. 22 (“Gillman Decl.”) ¶ 3. Defendants are federal agencies and officers residing in both Washington, D.C. and in the Western District of New York. Dkt. No. 31 (“Mem.”) at 6; Compl. ¶¶ 11–15. Defendant United States Department of Homeland Security (“DHS”) oversees the national immigration-detention system. Compl. ¶¶ 11–12. Defendant United States Immigration and Customs Enforcement (“ICE”) is the DHS subagency that operates BFDF. Id. BFDF is located in Batavia, New York in Genesee County, which lies in the Western District of New York. Gillman Decl. ¶ 11. At BFDF, non-citizens charged with violating federal immigration law are detained for immigration proceedings and removal from the United States.

Dkt. No. 46 (“Harvey Decl.”) at ¶ 5. In November 2024, following an alleged increase in mail containing drugs and synthetic substances, Harvey Decl. at ¶ 23, Defendants reinstituted, and expanded the scope of, a “legal mail policy” at BFDF. Compl. ¶¶ 2–3. Under this expanded policy, ICE officers “inspect, copy, and retain all legal mail” sent to or from individuals detained at BFDF “by any means,” including “documents given in-person” by attorneys meeting with clients at BFDF. Id. ¶¶ 2–3. The policy “applies categorically to all incoming and outgoing” correspondence at BFDF, including privileged correspondence between attorneys and clients. Id. ¶¶ 2–3. Since the policy was reinstated, Plaintiffs no longer “send legal mail to [their] clients” detained at BFDF, Gillman Decl. ¶ 9, and are wary of “handing over written documents during visits because doing so invites document review and retention by ICE officers.” Nowak Decl. ¶ 5. Instead, Plaintiffs “rely more on in-person visits to

orally communicate with clients,” and “have opted to read documents to clients rather than hand over written documents,” id. ¶¶ 6, 7, incurring additional expenses and expending additional time to do so. Id. ¶¶ 7–8; Belsher Decl. ¶¶ 8–9. Plaintiffs assert that the policy “has interfered with the[ir] ability . . . to communicate freely and effectively with their clients” and interfered with the effective provisions of legal services to those clients.” Compl. ¶¶ 32, 34. B. Procedural History Plaintiffs filed this action on March 10, 2025, asserting claims for violations of the First Amendment and the APA, 5 U.S.C. § 706(2)(a). Id. ¶¶ 39–45. Although the complaint asserts that “[v]enue is proper under 28 U.S.C. § 1391(b), (e),”—it does not assert that any fact or conduct underlying Plaintiffs’ claims took place in Manhattan. Id. ¶ 3. On March 11, 2025, the Court ordered Plaintiffs to show cause as to why this case should not be transferred to the Western District of New York given that the “entire case arises from alleged conduct at BFDF in Genesee County,” which lies in that district. Dkt. No. 8 (the “OTSC”),

at 2 (citing 28 U.S.C. § 112(d)). On April 4, 2025, Plaintiffs filed their response, in which they make the same arguments they make in their opposition to Defendants’ motion to transfer this case. Compare Dkt. No. 21 (“OTSC Resp.”), with Dkt. No. 32 (“Opp’n”). In support of their response, Plaintiffs submitted three declarations from: (1) Sarah T. Gillman, Director of Strategic United States Litigation, United States Advocacy and Litigation at RFKHR; (2) Jillian Nowak, attorney at PLSNY; and (3) Amy Belsher, Senior Staff Attorney at NYCLU. See Gillman Decl.; Nowak Decl.; Belsher Decl. These declarations highlight that, following the implementation of the legal mail policy, Plaintiffs stopped communicating with their clients by mail, Gillman Decl. ¶ 9; Nowak Decl. ¶ 7, and now “rely more on in-person visits to orally communicate with clients.” Nowak Decl. ¶ 7. All three declarants attest that this “de facto” travel requirement imposes significant “time and monetary” burdens on the nonprofit Plaintiffs, which already operate on limited budgets. Gillman

Decl. ¶ 11; Nowak Decl. ¶ 6; Belsher Decl. ¶ 8. On April 6, 2025, the Court declined either to take further action on the order to show cause or to determine, on its own initiative, whether this case should be transferred. Dkt. No. 25. However, the Court stated it would consider any motion to transfer this case brought by Defendants. On April 28, 2025, Defendants filed a motion to transfer this case to the United States District Court for the Western District of New York pursuant to 28 U.S.C § 1404(a). See generally Mem. In their motion, Defendants argue that this action should be transferred because all the operative facts giving rise to Plaintiffs’ claims occurred in the Western District of New York and because that district is more convenient for both party and non-party witnesses. Id. at 1.

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Prisoners' Legal Services of New York v. U.S. Department of Homeland Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prisoners-legal-services-of-new-york-v-us-department-of-homeland-nywd-2025.