ST. LOUIS — A federal judge has dismissed a lawsuit against the Center for Behavioral Medicine in Kansas City finding that the case was filed in the wrong federal district and that the plaintiff’s amended complaint did not state facts supporting a legal claim.
U.S. District Judge Henry Edward Autrey issued the opinion. The dismissal was entered without prejudice, meaning the court’s ruling did not constitute a dismissal on the merits that would prevent the matter from being pursued again in an appropriate proceeding.
Craig King filed the lawsuit while residing at the Center for Behavioral Medicine in Kansas City. The court said the amended complaint was filed using a form intended for prisoner civil rights complaints under 42 U.S.C. § 1983.
According to the court, however, King left most of the form incomplete, including sections requesting a statement of the claim, information about injuries and the relief being sought.
The court determined that the lawsuit had been filed in the wrong venue because both King’s residence and the location of the sole defendant were in Kansas City. Kansas City is located in Jackson County, which the court noted is within the Western District of Missouri rather than the Eastern District of Missouri.
Federal law governing venue provides that a civil action may generally be brought in a judicial district where a defendant resides, where a substantial portion of the events involved in the case occurred, or, under certain circumstances, where a defendant is subject to the court’s jurisdiction.
The judge concluded that venue was proper in the Western District of Missouri because the defendant is located there.
The court considered whether the case should be transferred to the Western District rather than dismissed. Autrey concluded that a transfer was not in the interest of justice because the amended complaint was incomplete and did not adequately identify a claim.
In the amended complaint, King responded to a question concerning exhaustion of administrative remedies by stating, “[B]reaking a HIPAA law,” according to the court.
The judge characterized that statement as a legal conclusion rather than an explanation of facts. The court said King did not provide factual allegations in the section asking him to describe the basis of his claims.
The court ultimately determined that King had not alleged facts or asserted plausible legal claims in his amended complaint. As a result, the judge found that the complaint failed to state a claim upon which relief could be granted.
The court therefore dismissed the case under 28 U.S.C. § 1406(a), the federal statute addressing cases filed in an improper venue.
The dismissal was specifically entered “without prejudice.” The court also denied as moot King’s motion for permission to proceed in forma pauperis, a request concerning court fees for a person who cannot afford them.
The order stated that a separate order of dismissal would accompany the court’s opinion.
The court’s ruling addressed the filing’s venue and pleading deficiencies and did not make factual findings resolving the underlying allegations because the court found that no plausible legal claim had been adequately presented in the amended complaint.
U.S. District Court for the Eastern District of Missouri, Southeastern Division case number: 1:26-cv-00148
