District Court Grants Insurer’s Motion to Transfer Venue in ERISA Benefits Action Finding Significant Connection to Transferee District

In Cline v. Prudential Ins. Co. of Am., No. 23-CV-15091, 2024 WL 3455089 (N.D. Ill. July 18, 2024), Illinois Northern District Judge Sharon Johnson Coleman, granted Defendant Prudential’s motion to transfer venue to the Middle District of Tennessee, finding that significant connections between the case and the transferee court warranted transferring the case in the interest of justice.

This case arises from Prudential’s denial of Plaintiff’s long-term disability claim. Plaintiff is a resident of Franklin, Tennessee where he seemingly resided during all relevant time periods. Plaintiff asserts that venue is proper in the Northern District of Illinois because Prudential “may be found” within the District. Prudential moved to transfer the case to the Middle District of Tennessee pursuant to 28 U.S.C. § 1404(a) asserting that the forum is more convenient. The Court concluded that while it was undisputed that venue and jurisdiction were proper in both Illinois and Tennessee, the Middle District of Tennessee was the more convenient forum.

The Court first considered the following “private interests” factors: (1) the plaintiff’s choice of forum; (2) the situs of the material events; (3) the relative ease of access to sources of proof; (4) the convenience of the parties; and (5) the convenience of the witnesses. It noted that all factors, save Plaintiff’s choice of forum weighed in favor of transfer. And while Plaintiff’s choice of venue should generally be given deference, where a plaintiff does not reside in the chosen forum, the deference owed to his choice is substantially reduced.

The Court next considered the “public interests” factors which focus on the efficient administration of the court system, including: (1) the speed at which the case will proceed to trial; (2) the court’s familiarity with the applicable law; (3) the relation of the community to the occurrence at issue; and (4) the desirability of resolving controversies in their locale. It noted that the first two factors were neutral as both venues are equally capable of handling this ERISA matter in terms of capacity and substance. However, the Court concluded that the third and fourth factors weighed in favor of transfer, as the events occurred in Tennessee and the relation to the community and desirability to resolve controversies in their locale supported a change in venue.

In granting the motion, the Court noted Plaintiff’s suggestion that because his counsel lived in Illinois and because ERISA provides any action be brought where a Defendant “may be found” warranted denial of the motion to transfer did not recognize the significant connections between the case and the transferee court making it quite clear that the Middle District of Tennessee is the more convenient venue.

If Prudential or your insurer has denied or otherwise limited your life or disability insurance claim, contact us for assistance.