Background
Ronald Satish Emrit, proceeding pro se, filed a notice of appeal approximately four months after his civil case was transferred from the Western District of Tennessee to the Eastern District of Virginia. The appeal was filed before the district court entered any other orders. Emrit sought to appeal the transfer order itself.
The court’s reasoning
The court explained that it has no jurisdiction to review a decision to transfer venue rendered by a district court in another circuit. Additionally, the notice of appeal was filed outside the applicable sixty-day appeal period. Finally, the appeal was not taken from a final order or another appealable interlocutory or collateral order.
[W]e have no jurisdiction to review a decision to transfer venue rendered by a district court in another circuit.
Brock v. Entre Comput. Ctrs., Inc., 933 F.2d 1253, 1257 (4th Cir. 1991)
What it means going forward
The dismissal prevents review of the venue transfer. The court noted that if the litigant wishes to appeal a subsequent dismissal order, he must file a new notice of appeal.