In Re Anant Kumar Tripati, 836 F.2d 1406 (D.C. Cir. 1988). · Go Syfert
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In Re Anant Kumar Tripati, 836 F.2d 1406 (D.C. Cir. 1988). Cases Citing This Book View Copy Cite
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cited 4× by 4 distinct cases · 2 courts · …transfer is indeed appropriate . . . to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another. at p. 1407 ✓
33 citation events (22 in the last 25 years) across 10 distinct courts.
Strongest positive: Drake v. State Farm Mutual Automobile Insurance Company (ded, 2025-01-29)
Treatment trajectory · 1991 → 2026 · click a year to view as-of
1991 2008 2026
Top citers, strongest first. 27 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Drake v. State Farm Mutual Automobile Insurance Company
D. Del. · 2025 · signal: see also · quote attribution · 1 verbatim quote · confidence high
transfer is indeed appropriate . . . to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another.
discussed Cited as authority (verbatim quote) Drake v. State Farm Mutual Automobile Insurance Company
N.D. Tex. · 2025 · signal: see also · quote attribution · 1 verbatim quote · confidence high
transfer is indeed appropriate . . . to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another.
discussed Cited as authority (verbatim quote) Drake v. FedEx Ground Package System Inc
N.D. Tex. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
transfer is indeed appropriate . . . to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another.
discussed Cited as authority (verbatim quote) Drake v. FedEx Ground Package System Inc.
D. Del. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
transfer is indeed appropriate . . . to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another.
discussed Cited as authority (verbatim quote) United States v. Hines
D.D.C. · 2019 · quote attribution · 1 verbatim quote · confidence high
a habeas petition may be adjudicated only in the district in which petitioner's immediate custodian, his warden, is located.
discussed Cited as authority (rule) Rune Kraft v. CRH PLC (2×) also: Cited "see"
C.D. Cal. · 2021 · confidence medium
Faced with motions to dismiss 5 and to deem him a vexatious litigant, Mr. Kraft then filed the 630-page FAC, (Doc. 72), 6 which is the subject of this order. 7 To quote the Northern District of California court, this case is another effort to use 8 one district court “as a safe haven from the lawful orders of another.” See Kraft, 2018 WL 9 3777563, at *3 (quoting In re Tripati, 836 F.2d 1406, 1407 (D.C.
discussed Cited as authority (rule) Kraft v. CRH PLC (2×) also: Cited "see"
D. Ariz. · 2021 · confidence medium
Faced with motions to dismiss 5 and to deem him a vexatious litigant, Mr. Kraft then filed the 630-page FAC, (Doc. 72), 6 which is the subject of this order. 7 To quote the Northern District of California court, this case is another effort to use 8 one district court “as a safe haven from the lawful orders of another.” See Kraft, 2018 WL 9 3777563, at *3 (quoting In re Tripati, 836 F.2d 1406, 1407 (D.C.
discussed Cited as authority (rule) Lopez-Pena v. Barr
D.D.C. · 2021 · confidence medium
Cir. 2006), the general rule is that a § 2241 motion must be brought in the judicial district where the prisoner is incarcerated—that is, the judicial district in which the custodian resides, see, e.g., In re Tripati, 836 F.2d 1406, 1407 (D.C.
discussed Cited as authority (rule) Marks v. Torres
D.D.C. · 2008 · confidence medium
Transfer “avoid[s] the prospect of a litigant using one district court as a safe haven from the lawful orders of another.” In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam); see Reddy v. O’Connor, 520 F.Supp.2d 124, 133 (D.D.C.2007) (transferring action under § 1404(a) to the district where plaintiff and “virtually all of the remaining named parties are located,” notwithstanding “the adverse decisions she has thus far received in those courts, including an order that limits her ability to file suit without leave of court”); Mikkilineni v. Penn Nat’l Mut.
discussed Cited as authority (rule) In Re: Billy Asemani
D.C. Cir. · 2006 · confidence medium
Transfer was warranted, DHS claimed, because Asemani was incarcerated in the Eastern District of Pennsylvania and therefore the D.C. district court lacked jurisdiction over his custodian. 8 Id. at 2 (citing In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (“A habeas petition may be adjudicated only in the district in which [petitioner’s] immediate custodian, his warden, is located.”)).
discussed Cited as authority (rule) Forrester v. United States Parole Commission
D.D.C. · 2004 · confidence medium
That person is the only one who can directly produce 'the body’ of the petitioner.” Id. at 416 ; see also Chatman-Bey, 864 F.2d at 811 ("[T]he proper defendant in federal habeas cases is the [petitioner’s] warden.”); In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) ("A habeas petition may be adjudicated only in the district in which [the petitioner's] immediate custodian, his warden, is located.”) (citing Guerra, 786 F.2d at 414 ). 13 .
discussed Cited as authority (rule) Mikkilineni v. Penn National Mutual Casualty Insurance
D.D.C. · 2003 · confidence medium
In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (transferring case to a district that had heard earlier cases by the plaintiff and barred the plaintiff from filing additional complaints without leave). 2.
cited Cited as authority (rule) 96 Cal. Daily Op. Serv. 2674, 96 Daily Journal D.A.R. 4438, 96 Daily Journal D.A.R. 5369 Jose Ortiz-Sandoval v. James Gomez, Director of Corrections for the State of California
9th Cir. · 1996 · confidence medium
See, e.g., Yi v. Maugans, 24 F.3d 500, 507 (3rd Cir.1994); In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
cited Cited as authority (rule) Ortiz-Sandoval v. Gomez
9th Cir. · 1996 · confidence medium
See, e.g., Yi v. Maugans, 24 F.3d 500, 507 (3rd Cir.1994); In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
cited Cited as authority (rule) Donald Gene Henthorn v. Michael J. Quinlan, Director Bureau of Prisons
D.C. Cir. · 1992 · confidence medium
In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam).
cited Cited as authority (rule) In Re Douglas Henry Thornton
D.C. Cir. · 1992 · confidence medium
In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
cited Cited as authority (rule) Donald Gene Henthorne v. Michael J. Quinlan, Director, Bureau of Prisons
D.C. Cir. · 1992 · confidence medium
In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
discussed Cited as authority (rule) Donald Gene Henthorn v. John C. Lawn, Director of the Drug Enforcement Administration
D.C. Cir. · 1992 · confidence medium
"The writ will issue to block a transfer only if the court concludes, upon review of the entire record, that the district court grossly abused its discretion." In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
discussed Cited as authority (rule) In Re Francis Ferri
D.C. Cir. · 1992 · confidence medium
"The writ will issue to block a transfer only if the court concludes, upon review of the entire record, that the district court grossly abused its discretion." In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988).
discussed Cited as authority (rule) Peon v. Thornburgh
S.D.N.Y. · 1991 · confidence medium
See ibid.; In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam) (petition must be brought in district in which petitioner’s custodian is located); Hassain v. Johnson, 790 F.2d 1420, 1420 (9th Cir.1986) (per curiam) (same), cert. denied, 479 U.S. 1038 , 107 S.Ct. 893 , 93 L.Ed.2d 845 (1987).
cited Cited "see" Scinto v. Federal Bureau of Prisons
D.C. Cir. · 2009 · signal: see · confidence high
See In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam).
cited Cited "see" Scinto v. Federal Bureau of Prisons
D.C. Cir. · 2009 · signal: see · confidence high
See In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam).
discussed Cited "see" Anant Kumar Tripati v. Department of Justice
D.C. Cir. · 1991 · signal: see · confidence high
See In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988) (per curiam). 3 The Clerk is directed to withhold issuance of the mandate herein until seven days after disposition of any timely petition for rehearing.
discussed Cited "see, e.g." Troster v. Barr
D.D.C. · 2021 · signal: see also · confidence medium
Co., 499 U.S. 244, 256 (1991), and aligns with the general rule that venue must lie where “a substantial part of the events or omissions giving rise to the claim occurred,” 28 U.S.C. § 1391 (b)(2); see also In re Tripati, 836 F.2d 1406, 1407 (D.C.
discussed Cited "see, e.g." In Re Volkswagen of America, Inc.
5th Cir. · 2008 · signal: see, e.g. · confidence medium
See, e.g., In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988); A. Olinick & Sons v. Dempster Bros., Inc., 365 F.2d 439, 444-45 (2d Cir. 1966); In re Ralston Purina Co., 726 F.2d 1002 , 1006 (4th Cir.1984); ACF Indus., Inc. v. Guinn, 384 F.2d 15, 19-20 (5th Cir. 1967); In re Oswalt, 607 F.2d 645, 647 (5th Cir. 1979); In re McDonnell-Douglas Corp., 647 F.2d 515, 517 (5th Cir. Unit A May 1981); Castanho v. Jackson Marine, Inc., 650 F.2d 546, 550 (5th Cir. Unit A June 1981); In re First S. Sav.
discussed Cited "see, e.g." In re Volkswagen of America, Inc.
5th Cir. · 2008 · signal: see, e.g. · confidence medium
See, e.g., In re Tripati, 836 F.2d 1406, 1407 (D.C.Cir.1988); A. Olinick & Sons v. Dempster Bros., Inc., 365 F.2d 439, 444-45 (2d Cir. 1966); In re Ralston Purina Co., 726 F.2d 1002, 1006 (4th Cir. 1984); ACF Indus., Inc. v. Guinn, 384 F.2d 15, 19-20 (5th Cir.1967); In re Oswalt, 607 F.2d 645, 647 (5th Cir. 1979); In re McDonnell-Douglas Corp., 647 F.2d 515, 517 (5th Cir. Unit A May 1981); Castanho v. Jackson Marine, Inc., 650 F.2d 546, 550 (5th Cir. Unit A June 1981); In re First S. Sav.
discussed Cited "see, e.g." Wells v. Liddy
D.D.C. · 2000 · signal: see, e.g. · confidence low
See e.g., In Re Tripati, 836 F.2d 1406 (D.C.Cir.1988); Starnes v. McGuire, 512 F.2d 918 (D.C.Cir.1974); and it is further ORDERED that the above-captioned case shall be TRANSFERRED to the United States District Court for the District of Maryland pursuant to this Court’s February 24, 2000 order.
Retrieving the full opinion text from the archive…
In Re Anant Kumar TRIPATI, Petitioner
87-5382.
Court of Appeals for the D.C. Circuit.
Jan 22, 1988.
836 F.2d 1406
1988 U.S. App. LEXIS 581
1988 WL 3045
Anant Kumar Tripati, pro se.
Ginsburg, Starr, Buckley.
Cited by 30 opinions  |  Published

Opinion for the Court filed PER CURIAM.

PER CURIAM:

Petitioner Anant Kumar Tripati, currently incarcerated in the Federal Correctional Institution in Tucson, Arizona, has petitioned the court to issue a writ of mandamus. Tripati seeks to overturn an order of the district court transferring this lawsuit to the United States District Court for the District of Arizona. Because the district court did not abuse its discretion in ordering the case transferred, the petition is denied.

On May 13, 1987, Tripati filed a complaint for declaratory relief in the district court. Purporting to represent a class of “each and every Federal Prisoner, past, current [and] future,” Tripati asserted, inter alia, violations of his sixth amendment rights. These violations allegedly stemmed from the government’s failure to inform “accused individuals,” including Tripati, of their right to self representation.

Tripati also alleged denial of access to legal materials, disabling him from ade[*1407] quately pursuing review of his convictions. Specifically, he claimed that because his convictions “resultfed] from complex technical banking, insurance, securities and investment transactions,” the available legal materials were plainly inadequate to allow him to challenge his convictions effectively.

Tripati moved for summary judgment. While the motion was pending, the government moved to have the case transferred to the federal district court in Arizona. Tripa-ti opposed the motion, arguing that the lawsuit challenged “policies formulated in this district.” The district court, on October 27, 1987, ordered transfer of the case to Arizona.

Mandamus is an extraordinary remedy to be granted only where essential to the interests of justice. Starnes v. McGuire, 512 F.2d 918, 929 (D.C.Cir.1974) (en banc). The writ will issue to block a transfer only if the court concludes, upon review of the entire record, that the district court grossly abused its discretion. Id. No such abuse occurred here.

As already noted, Tripati is incarcerated in the federal correctional facility in Tucson, Arizona. A prolific pro se litigant, Tripati has filed numerous civil actions in the federal district court in Arizona. Because his filings there have been so numerous, that district court ordered its clerk not to accept any complaint or petition from Tripati except pursuant to an order of a judge of the court. This measure was intended to insure that a judicial officer would review Tripati’s claims to ascertain whether they duplicated other pending actions filed by him.

In the instant case, the district court reasonably could have concluded that transfer was appropriate because of Tripa-ti’s apparent attempt to avoid the threshold checkpoint his complaint would encounter in the Arizona district court. Transfer is indeed appropriate in such a situation to avoid the prospect of a litigant using one district court as a safe haven from the lawful orders of another.

Moreover, the Arizona district court has found, on two previous occasions, that the law library at FCI-Tucson is constitutionally adequate. See Tripati v. Henman, No. 86-231 (D.Ariz. April 14, 1987); Tripati v. Henman, No. 85-170 (D.Ariz. May 13, 1987). In addition, to the extent that Tripati complains that his incarceration is illegal, that complaint is properly presented only by a petition for a writ of habeas corpus. A habeas petition may be adjudicated only in the district in which Tripati’s immediate custodian, his warden, is located. See Guerra v. Meese, 786 F.2d 414 (D.C.Cir.1986).

Finally, the expeditious final resolution of this controversy will be advanced in the transferee forum due to its familiarity with the related civil suits filed there by Tripati. This consideration further supports the transfer. See Starnes v. McGuire, 512 F.2d at 932.

For the reasons stated, the petition for a writ of mandamus is

Denied.