ERISA-District Court Discusses And Approves Transfer Of Venue

The case of Youngblood v. Life Ins. Co. of North America, 2016 U.S. Dist. LEXIS 50081 (W.D. Ky 2016), came before the District Court (the “Court”) upon the motion to transfer venue filed by defendant Life Insurance Company of North America (“LINA”).

The case arises out of the claim of plaintiff Janice Youngblood (“Youngblood”), under ERISA, for long-term disability benefits from a policy issued and administered by LINA. Youngblood is a resident of Winfield, Alabama, which is located in the Northern District of Alabama. Youngblood worked for Joy Global, Inc. (“Joy Global”), a company headquartered in Milwaukee, Wisconsin. However, Youngblood worked for a Joy Global office located in Alabama. In support of her claim, Youngblood submitted medical records from her doctors who are also located in Alabama. LINA is a Pennsylvania company with its principal place of business in Philadelphia. Youngblood filed this action in the Western District of Kentucky. LINA now moves to transfer this case to the Northern District of Alabama. Youngblood request that this case remain in Kentucky or, alternatively, be transferred to the Eastern District of Wisconsin.

 

In analyzing the case, the Court noted that the law (28 U.S.C. § 1404(a)) provides that, for the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought. The Court then concluded that (i) venue is proper in both the Northern District of Alabama and the Eastern District of Wisconsin and (ii) the interest of justice and convenience to parties and witnesses weigh in favor of a transfer to the Northern District of Alabama.

 

As to (i), the Court said that venue in an ERISA action is proper in any district where the plan is administered, where the breach took place, or where a defendant resides or may be found (29 U.S.C. § 1132(e)(2)).  In turn, citing case law, the Court said that a defendant resides or may be found, for ERISA venue purposes, in any district in which its minimum contacts would support the exercise of personal jurisdiction. As such, in this case, venue is proper in the Eastern District of Wisconsin because that is where the plan is administered, and in the Northern District of Alabama because that is the location of where the breach took place.

 

As to (ii), the Court said that transferring the venue to the Northern District of Alabama is appropriate, since that district has a strong interest in this case, the witnesses and doctors are located in Alabama, and that district is where Youngblood resides and where the alleged breach occurred.

 

 

 

 

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