Layfield v. Unum Life Insurance Company of America

Background

Jennifer Layfield brought an action under the Employee Retirement Income Security Act of 1974, commonly called ERISA, seeking long-term disability benefits under an employee benefit plan. She most recently worked for DLA Piper, LLP. Layfield alleged that she contracted COVID-19 in December 2020, developed long-term COVID-19, and could not return to full-time work. She submitted a benefits claim to Unum Life Insurance Company of America, and Unum denied it.

Layfield resided in Pacific Palisades, in the Central District of California. She was the only member of her practice team based near her home, while the rest of the team worked from DLA Piper’s San Francisco office. Her medical providers were in Los Angeles. DLA Piper was headquartered in Maryland, and Unum was based in Maine.

Motion to Transfer

Unum moved under 28 U.S.C. § 1404(a) to transfer the case to the Central District of California for the convenience of the parties. Unum conceded that venue was proper in the Northern District under ERISA’s venue provision but argued that the case should nevertheless be transferred.

The court explained that a transfer under § 1404(a) requires first determining whether the case could have been brought in the proposed district. If so, the court weighs factors including the parties’ and witnesses’ convenience, the plaintiff’s choice of forum, local interest in the dispute, and the interests of justice. The party seeking transfer must make a strong showing of inconvenience.

Court’s Analysis

The court gave Layfield’s choice of the Northern District only minimal weight. Layfield did not live there, she was diagnosed and treated in the Central District, and none of the case’s events occurred in the Northern District. The court viewed her remote work from Southern California for a Maryland-headquartered firm’s San Francisco office as only a tenuous connection to the Northern District and concluded that her choice of forum was forum shopping.

The convenience factor weighed at least minimally in favor of transfer. The case would likely focus on an administrative record and involve limited discovery, but Unum might seek to interview or depose approximately seven medical professionals in the Los Angeles area. The court also noted that the Northern District would have limited ability to enforce discovery involving third-party witnesses located elsewhere.

The court found that the Central District had a substantially greater local interest because Layfield lived there, was diagnosed and treated there, and no part of Unum’s benefits denial took place in the Northern District.

Disposition

After considering the factors as a whole, the court concluded that the case belonged in the Central District of California, where Layfield and potential witnesses resided and where the dispute had a stronger local connection. The court GRANTED Unum’s motion to transfer venue. The order addressed venue and convenience; it did not decide the merits of Layfield’s claim for long-term disability benefits.