Hamer v. JP Morgan Chase Long-term Disability Benefit Plan

Background

This is an employee-benefits dispute under the Employee Retirement Income Security Act (ERISA). Kenneth S. Morrison, a deceased former Chase vice president and head options trader, became permanently disabled after being struck by a taxi in 1995. He lived in Connecticut, worked in New York City, and received long-term disability benefits from Chase’s employee plan from 1996 until his death in March 2022.

The plan provided benefits equal to 60 percent of the employee’s monthly base salary when the disability began. Chase initially listed Morrison’s monthly base salary as $100,000, resulting in a $5,000 monthly benefit. Hamer alleges that Chase should have included Morrison’s $200,000 nondiscretionary shift differential, which would have produced a $15,000 monthly benefit. Hamer also alleges that Chase knew about the error by 2003 and that the defendants mishandled his later administrative claim and appeal.

Hamer is the successor trustee of Morrison’s special-needs trust and the co-conservator of his estate. He lives in San Francisco. The complaint asserts six ERISA claims: two seeking monetary relief and four alternative claims seeking equitable relief, such as changes to claims-handling procedures.

Motions

The defendants filed a motion to partially dismiss the four equitable-relief claims under Federal Rule of Civil Procedure 12(b)(1), asserting that Hamer lacked standing, and Rule 12(b)(6), asserting that the claims were time-barred or barred because monetary relief was available. They also moved to transfer the case to the District of Connecticut under 28 U.S.C. § 1404(a), which permits transfer for the convenience of the parties and witnesses and in the interest of justice.

The court decided only the transfer motion. It explained that courts commonly leave Rule 12(b)(6) motions for the court receiving a transferred case. Although the standing motion raised a jurisdictional issue, the court concluded that the case could still have been brought in Connecticut because several claims would remain within that court’s subject-matter jurisdiction even if the standing motion were granted.

Transfer analysis

Hamer did not dispute that the case could have been filed in the District of Connecticut. The court therefore focused on convenience and the interests of justice. It gave Hamer’s choice of the Northern District of California only minimal weight because the operative facts and the dispute’s strongest connections were elsewhere.

The court found that Morrison lived in Connecticut, received his medical treatment and benefits there for 27 years, and had a conservator, attorneys, and a probate court connected to Connecticut. Chase and Prudential also had relevant connections near Connecticut: Chase’s principal place of business was in New York City, and Prudential was headquartered in Newark, New Jersey and maintained offices in Connecticut. The court also found that the alleged underpayment harmed Morrison, the plan participant, in Connecticut.

The court recognized California’s connections. Hamer lived in San Francisco, the trust’s assets were held there before disbursement, Hamer and another trustee managed and distributed benefits there, and Hamer pursued the administrative claim from San Francisco. But the court characterized California as functioning mainly as a conduit for benefits whose intended recipient and factual center were in Connecticut. It also found that Connecticut had the greater local interest and that the convenience of the parties and witnesses favored Connecticut because Douglas Morrison was there, the defendants were headquartered near there, and Hamer was the only identified relevant person in California. The remaining transfer factors were neutral.

Disposition

The court granted the defendants’ motion to transfer venue to the District of Connecticut under § 1404(a). It transferred the case and declined to decide the motion to dismiss. The order resolved ECF Nos. 19 and 26.