H. v. United Healthcare Insurance Company
- Richard Seeborg
- 3:24-cv-05183
- U.S. District Court · Northern District of California
- 2
In Sean H. and A.H. v. UnitedHealthcare Insurance Company, Judge Shelby granted an unopposed motion transferring the ERISA case to Northern California.
The case brought by Sean H. and A.H. against UnitedHealthcare Insurance Company, United Behavioral Health, Cruise LLC, and the Cruise LLC Welfare Benefit Plan was transferred from the District of Utah to the Northern District of California.
What happened
Sean H. and A.H. sued UnitedHealthcare Insurance Company, United Behavioral Health, Cruise LLC, and the Cruise LLC Welfare Benefit Plan over employee-benefit and mental-health coverage claims.
The defendants asked to move the case from Utah to the Northern District of California. The plaintiffs did not respond, and the court also found that the convenience and fairness factors favored transferring the case.
Chief District Judge Robert J. Shelby granted the motion and directed the clerk to transfer the case to the U.S. District Court for the Northern District of California. The order did not decide the underlying benefits or damages claims.
The detailed version
- H. v. United Healthcare Insurance Company · No. 3:24-cv-05183
- Richard Seeborg
- Aug. 14, 2024
Background
Sean H. and A.H., a minor, brought claims against UnitedHealthcare Insurance Company, United Behavioral Health, Cruise LLC, and the Cruise LLC Welfare Benefit Plan. The complaint sought recovery of benefits under the Employee Retirement Income Security Act (ERISA), damages for alleged violations of the Mental Health Parity and Addiction Equity Act of 2008, and statutory penalties.
The defendants moved under 28 U.S.C. § 1404(a) to transfer the case from the District of Utah to the Northern District of California. The motion was filed on July 8, 2024. The plaintiffs did not file a response by the July 22 deadline, and they also did not respond when the court asked whether the motion was contested.
Court’s analysis
The court stated that a case may be transferred under Section 1404(a) when the new district is one where the case could have been filed and the transfer would serve the convenience of the parties and witnesses and the interests of justice. The court found that the action could have originally been brought in the Northern District of California, where the opinion states that the plaintiffs live.
The court considered the relevant convenience and justice factors, including the plaintiffs’ choice of forum, access to witnesses and evidence, the cost of presenting proof, the enforceability of a judgment, the possibility of a fair trial, docket congestion, conflicts of law, local-law issues, and other practical considerations. It agreed with the defendants that the balance of factors favored transfer. Separately, the court noted that the plaintiffs’ failure to respond could itself support granting the motion under the local rules.
Ruling
Chief District Judge Robert J. Shelby granted the defendants’ unopposed motion to transfer venue. The clerk was directed to transfer the case to the United States District Court for the Northern District of California. The order addressed venue only and did not decide the merits of the plaintiffs’ ERISA, mental-health-parity, or statutory-penalty claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.