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Opinion

govinfo:USCOURTS-dcd-1_26-cv-01591-0

U.S. District Court for the District of Columbia · 2026-05-21

· GavelSight synced 2026-09-06 03:52:30

UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 
 
 
JENNIFER M. ROLLS, 
 
 Plaintiff, 
 
 v. 
 
TROY E. MEINK, 
Secretary of the Air Force, 
 
 Defendant. 
 
Civil Action No. 26-01591 (AHA) 
 
 
 
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 Virg inia 
based on improper venue . ECF No. 8. Given Rolls’ emergency motion, the court set expedited 
briefing on that motion and the gove rnment’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 

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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 th e 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 

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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))). 

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