R. v. Blue Shield of California

Background

R.R. and E.R. brought an action under the Employee Retirement Income Security Act (ERISA) against Blue Shield of California. The parties filed a stipulated motion to transfer venue from the District of Utah to the Northern District of California.

Legal standard

Under 28 U.S.C. § 1404(a), a federal district court may transfer a civil action for the convenience of the parties and witnesses and in the interest of justice when the case could have been brought in the proposed transferee district. For an ERISA action, 29 U.S.C. § 1132(e)(2) allows the case to be brought where the plan is administered, where the alleged breach occurred, or where the defendant resides or may be found.

Court’s analysis

The court explained that the parties seeking transfer had to establish two elements: first, that the Northern District of California was a proper forum where the case could originally have been brought; and second, that transfer would improve convenience for the parties and witnesses and serve the interests of justice.

The parties’ supplemental briefing established the first element. They stated that Blue Shield is a California corporation, that the plan was administered in California, and that the plaintiffs, defendant, and plan could all be found in California. The parties stipulated to the second element, stating that transfer would save party resources and further judicial economy. The court accepted these joint assertions and agreement.

Disposition

The court granted the motion to transfer venue and ordered that the case be transferred to the Northern District of California. The order addressed venue only and did not decide the merits of the ERISA claims.