Rolls v. Meink

• Court: District Court, District of Columbia
• Decided: May 21, 2026
• Docket: Civil Action No. 2026-1591
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JENNIFER M. ROLLS,

Plaintiff, Civil Action No. 26-01591 (AHA) v.

TROY E. MEINK, Secretary of the Air Force,

Defendant.

Transfer Order

Jennifer Rolls sues the Air Force Secretary, challenging the decision to involuntarily curtail

her active-duty service and seeking a temporary restraining order, preliminary injunction, and 5

U.S.C. § 705 stay to prevent the curtailment from taking effect on May 31, 2026. ECF No. 4 at 1.

The Secretary quickly moved to dismiss or transfer the case to the Eastern District of Virginia

based on improper venue. ECF No. 8. Given Rolls’ emergency motion, the court set expedited

briefing on that motion and the government’s transfer motion. The court now grants the transfer

motion and orders that the case be transferred forthwith to the Eastern District of Virginia for

resolution of all further matters in the case.

Venue is proper in “any judicial district in which (A) a defendant in the action resides, (B)

a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part

of property that is the subject of the action is situated, or (C) the plaintiff resides if no real property

is involved in the action.” 28 U.S.C. § 1391(e)(1). If a case is filed in the wrong district, the district

court “shall dismiss, or if it be in the interest of justice, transfer such case to any district or division

in which it could have been brought.” 28 U.S.C. § 1406(a). The decision whether to dismiss or transfer “rests within the sound discretion of the district court.” Beckford v. Esper, No. 18-cv-940,

2018 WL 4778930, at *2 (D.D.C. Oct. 3, 2018) (quoting Naartex Consulting Corp. v. Watt, 722

F.2d 779, 789 (D.C. Cir. 1983)). And “the interest of justice generally requires transfer” rather

than dismissal. Id. (quoting Ellis-Smith v. Sec’y of Army, 793 F. Supp. 2d 173, 177 (D.D.C. 2011)).

Here, neither Rolls nor the Secretary resides in this district. Rolls lives in the Eastern

District of Virginia and is a resident of either Virginia or Nevada for venue purposes. See ECF No.

3 at 1; ECF No. 4-1 at 15–16; ECF No. 4-3 at 2. The Secretary resides in the Eastern District of

Virginia. See ECF No. 8 at 3–4; Nader v. Sec’y of the Air Force, 648 F. Supp. 3d 64, 68 (D.D.C.

2022) (“The Secretary of the Air Force’s residence is . . . the residence of the Air Force itself. And

the Air Force resides at the Pentagon, which is located in Arlington, Virginia, not the District of

Columbia.”). So venue is proper in D.C. only if “a substantial part of the events or omissions giving

rise to the claim occurred” here. 28 U.S.C. § 1391(e)(1).

That is not the case. Rolls’ claims challenge the decision to involuntarily curtail her active-

duty service and the process (or lack thereof) provided with respect to that decision. See ECF No.

3 ¶¶ 75–112. That process was initiated in January 2026, when Rolls was working in the Eastern

District of Virginia. See ECF No. 3 ¶ 42; ECF No. 10 at 3, 5; ECF No. 13 at 2. The Secretary

represents, and Rolls does not rebut, that the involuntary curtailment decision was made in the

Eastern District of Virginia. See ECF No. 13 at 5. To be sure, as Rolls argues, some of the conduct

she describes happened in D.C. According to her filings, Rolls worked in D.C. for substantial

periods over the last seven years and made complaints before she was moved to the Eastern District

of Virginia. See ECF No. 10 at 1–4. And she asserts that her team’s primary worksite moved to

D.C. again one day before the Air Force’s personnel office issued an amended order that reflected

her involuntary curtailment. See id. at 3, 5. But the fact remains that the curtailment decision was

2 made in the Eastern District of Virginia, Rolls worked there when the events giving rise to her

claims occurred, and no “substantial part” of those events happened in D.C. Venue is accordingly

improper here under 28 U.S.C. § 1391(e)(1). But venue is proper in the Eastern District of Virginia,

where the Secretary resides. 1

The court therefore grants the Secretary’s motion to transfer based on improper venue and

denies the Secretary’s motion to dismiss. ECF No. 8. The clerk of court is directed to transfer this

case to the Eastern District of Virginia forthwith.

AMIR H. ALI United States District Judge

Date: May 21, 2026

1 For similar reasons, even if venue were proper here, the court would exercise its discretion to transfer the case based on an individualized determination of “the convenience of parties and witnesses, in the interest of justice.” 28 U.S.C. § 1404(a). There is no question the case could have been brought in the Eastern District of Virginia—the Secretary resides there. Public interests favor transfer given that’s where most of the operative events occurred, that district’s familiarity with suits against the Air Force Secretary, and relative court congestion. See Correll v. U.S. Pat. & Trademark Off., No. 25-cv-1169, 2026 WL 310024, at *4 (D.D.C. Feb. 5, 2026) (reviewing recent statistics and concluding “courts in the Eastern District of Virginia are on average slightly less congested than this Court, which minorly weighs in favor of transfer”). And private factors lean that way too, given Rolls lives in the Eastern District of Virginia, the Secretary resides there, and the claims largely arose there. See Alaska Indus. Dev. & Exp. Auth. v. U.S. Dep’t of Interior, No. 23-cv-3126, 2024 WL 756602, at *5 (D.D.C. Feb. 23, 2024) (noting that the plaintiff’s choice of forum is entitled little deference when the defendant seeks transfer to a forum where the plaintiff has “substantial ties” and to which the “subject matter of the lawsuit is connected” (quoting Trout Unlimited v. U.S. Dep’t of Agric., 944 F. Supp. 13, 17 (D.D.C. 1996))).