E.V. v. United HealthCare Oxford

Background

E.V. and L.V. brought this action against United Healthcare Oxford and United Behavioral Health. The parties filed a stipulated motion to transfer the case from the United States District Court for the District of Utah to the United States District Court for the Southern District of New York.

The parties argued that transfer was appropriate because they had all consented, New York would be more convenient for the parties and witnesses, and transfer would serve the interests of justice. They also pointed to a forum-selection clause in the health plan. A forum-selection clause is a contract term identifying the place where disputes must be litigated. According to the opinion, the clause required disputes arising under the plan to be brought in a court located in New York.

Court’s Analysis

Under 28 U.S.C. § 1404(a), a federal court may transfer a civil case for the convenience of the parties and witnesses, in the interests of justice, or to a district to which all parties have consented. The court found that all parties had consented to transfer and concluded that the Southern District of New York would be more convenient and would serve the interests of justice.

The court noted that none of the parties resided in Utah. The motion described Oxford as the health plan’s insurer and claims administrator, a New York corporation domiciled in New York with its principal place of business in Connecticut. E.V. and L.V. were described as residents of New Jersey, and E.V.’s employer, which sponsored the health plan, was located in New York. United Behavioral Health was described as a California corporation with its principal place of business in San Francisco. Although Utah might have been more convenient for United Behavioral Health, that defendant consented to the transfer and had previously sought transfer to New York.

The court also stated that, even without the parties’ agreement, the forum-selection clause would likely require transfer to a federal court in New York. In a footnote, the court said defendants contended that the party sued as “United Healthcare Oxford” was actually “Oxford Health Plans (NY), Inc.” The court expressly offered no opinion on that contention and referred to the party as “Oxford” to avoid confusion.

Disposition

The court granted the parties’ stipulated motion and ordered that the action be transferred to the United States District Court for the Southern District of New York. The order addressed venue and transfer only; it did not resolve the underlying claims. Judge Jill N. Parrish entered the order.