United States District Court, D. New Hampshire
Jaideep S. Chawla
Michael J. Heffernan, in his official capacity as Commissioner of the Massachusetts Department of Revenue; U.S. Department of Justice; United States of America
J. McAULIFFE, UNITED STATES DISTRICT JUDGE
to an order dated June 28, 2018, document no. 29, the
above-captioned action was transferred to the United States
District Court for the District of Massachusetts and then
terminated as an action in this court. Jaideep Chawla, who
brought the above-captioned action, now moves this court to
reopen the case and: (1) give him an evidentiary hearing; (2)
inspect certain public records in camera; and (3)
“order . . . the Office of the Inspector General of the
U.S. Department of Justice to produce an audit report as to
all payments made under the [DOJ's] Equitable Sharing
Program to the Office of the Attorney General of the
Commonwealth [of Massachusetts] during the years 2014-2016,
” Mot. to Reopen (doc. no. 30) 1-2. The two federal
defendants object. For the reasons that follow, Chawla's
motion to reopen is denied, as is his pending motion to take
of background, it is undisputed that after Chawla's case
was transferred to the District of Massachusetts: (1) it was
assigned to Judge Sorokin; (2) Judge Sorokin dismissed
Chawla's claims and closed the case; and (3) Chawla
appealed Judge Sorokin's dismissal to the First Circuit,
where the appeal is now pending.
legal basis for the substantive relief he seeks in his
motion, i.e., a hearing, in camera review, and injunctive
relief, Chawla cites: (1) the federal
supplemental-jurisdiction statute, 28 U.S.C. § 1367; (2)
a Massachusetts public-records statute, Mass. Gen. Laws ch.
66, § 10A(d)(ii); and (3) “this Court's
inherent authority to ensure the due administration of the
law, ” Mot. to Reopen (doc. no. 30) 3. However, Chawla
does not explain how the court has jurisdiction over the
above-captioned action. Jurisdiction, in turn, is at issue
because this court transferred Chawla's case to the
District of Massachusetts.
respect to the effects of a transfer, a leading treatise
When a motion for transfer under 28 U.S.C.A. § 1404(a)
is granted and the papers are lodged with the clerk of the
transferee court, the transferor court . . . lose[s]
jurisdiction over the case and may not proceed further with
regard to it.
Charles Alan Wright et al., Federal Practice and
Procedure § 3846 (4th ed. 2014). The foregoing rule
has been recognized in this circuit. See, e.g., Walter v.
Isherwood Enters., Inc., No. 2:13-cv-00445, 2014 WL
2095207, at *5 (D. Me. May 20, 2014) (ruling that transferor
court “retained jurisdiction over [transferred] case
until [it] was received in [transferee] Court”);
PPG Indus., Inc. v. Webster Auto Parts, Inc., 849
F.Supp. 8, 9 (D. Mass. 1994) (ruling that where plaintiff
filed several motions in transferor court after transferee
court had docketed transferred case and assigned presiding
judge, transferor court lacked jurisdiction to entertain
plaintiff's motions) (citing In re Spillane, 884
F.2d 642, 645-56 (1st Cir. 1989)).
case was transferred to the District of Massachusetts under
28 U.S.C. § 1404(a). Once the papers were lodged with
the clerk of that court, this court lost jurisdiction over
Chawla's claims. Because this court lost jurisdiction
over Chawla's claims, and because nothing has happened to
restore jurisdiction, this court may not proceed any further
with regard to the above-captioned action.
Chawla's motion to reopen, document no. 30, is denied.
And, for that reason, his motion to take judicial notice,
document no. 31, is denied as moot.
 The rule divesting a federal court of
jurisdiction over a case it has transferred is also well
recognized outside this circuit. See, e.g., In re McGraw-Hill
Global Educ. Holdings LLC, 909 F.3d 48, 55-56 (3d Cir. 2018)
(explaining that transferor court retains jurisdiction over
transferred case only until transferee court proceeds with
the action); HealthTrio, Inc. v. Centennial River Corp.
(In re HealthTrio, Inc.),653 F.3d 1154, 1156 (10th Cir.
2011) (citing Hudson United Bank v. Chase Manhattan Bank
of Conn., N.A.,43 F.3d 843, 845 n.4 (3d Cir. 1994)
(explaining that transferor court loses jurisdiction once
transfer is complete, which occurs “when the files in a
case are ...