Guidehouse Inc. v. Continental Casualty Company

CourtDistrict Court, E.D. Virginia
DecidedSeptember 23, 2025
Docket1:25-cv-01601
StatusUnknown

This text of Guidehouse Inc. v. Continental Casualty Company (Guidehouse Inc. v. Continental Casualty Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Guidehouse Inc. v. Continental Casualty Company, (E.D. Va. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

GUIDEHOUSE INC., ) ) Plaintiff, ) No. 1:24-CV-12176 ) v. ) ) Judge Edmond E. Chang CONTINENTAL CASUALTY COMPANY, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Guidehouse Inc. sued its insurer, Continental Casualty Company, for breach of an insurance policy after Continental denied a claim for the cost of a settlement with the Department of Justice. R. 1, Compl.1 Guidehouse filed its suit in this Dis- trict, where Continental is based. Compl. ¶ 3, 5. But Continental filed a motion to transfer venue to the Eastern District of Virginia, where Guidehouse is based. Id. ¶ 2; R. 19, Def.’s Mot. For the reasons discussed in this Opinion, the motion to transfer is granted. I. Background To set the factual stage, the Opinion draws the allegations from the Complaint. See Compl. Continental issued an Enterprise Liability Policy to Guidehouse for the period covering October 2022 to October 2023 (“Policy”). Id. ¶ 29; R. 1-3, Exh. C, Policy

1Citations to the record are “R.” followed by the docket entry number and, if needed, a page or paragraph number. This Court has subject matter jurisdiction under diversity ju- risdiction. 28 U.S.C. § 1332(a). Complete diversity is met: Guidehouse is a citizen of Delaware and Virginia, and Continental is a citizen of Illinois. Compl. ¶¶ 2–3. The amount-in-contro- versy requirement is met because Guidehouse seeks to recover costs for defending itself in a qui tam lawsuit that ended with a $7.6 million settlement payment. Id. ¶ 24. at 1. The Policy includes technology and professional-liability coverage, and privacy- regulation investigation expense coverage. Compl. ¶ 31; Policy at 1. The Policy also includes a carve out from its coverage (“Deliberate Acts Exclusion”) for claims based

on a “dishonest, fraudulent, criminal or malicious act or omission, commingling, mis- appropriation or misuse of funds, intentional wrongdoing or knowing violation of any contract or agreement by or on behalf of [Guidehouse].” Compl. ¶ 40; Policy at 14–15. The Policy’s total maximum retention is $5,000,000. Compl. ¶ 32; Policy at 1. In 2021, Guidehouse entered into a contract with the New York Office of Tem- porary and Disability Assistance to help administer New York State’s emergency rental-assistance program (known in housing circles as ERAP) as established by Con-

gress. Compl. ¶¶ 7–9. The participating states implementing ERAP were required to take certain steps to safeguard the personally identifiable information of the land- lords and tenants applying to the program. Id. ¶ 8. Guidehouse was to be the “prime contractor,” tasked with developing the technology and online platform used by ap- plicants to apply for state rental assistance. Id. ¶ 9. The portal went live in June 2021—but just 12 hours after its launch, it was shut down because certain applicants’

personally identifiable information had been exposed. Id. ¶ 11. In February 2023, the DOJ issued a Civil Investigative Demand (commonly known by its acronym, CID) to Guidehouse to investigate the June 2021 privacy inci- dent. Id. ¶ 12. The CID was issued under the False Claims Act, 31 U.S.C. §§ 3729– 3733, and sought documents and answers related to the company’s cybersecurity and compliance with the terms of the ERAP contract. Id. In particular, the DOJ was 2 investigating allegations that Guidehouse (and its subcontractor) submitted or caused the submission of false claims in connection with their assistance in the im- plementation of the program. Compl. ¶ 13. About a year later, the DOJ issued a sec-

ond CID to Guidehouse seeking information about the company’s implementation of ERAP and other cybersecurity insight. Id. ¶ 18. At this time, the DOJ also disclosed to Guidehouse that the CIDs were connected to a qui tam complaint by a then-anon- ymous relator.2 Id. ¶ 17; R. 1-1, Exh. A, Relator’s Compl. Guidehouse provided notice of the CIDs to its insurer, Continental, and Conti- nental accepted the notices as a Notice of Circumstance. Compl. ¶¶ 14–15; 18–19. Guidehouse then entered into settlement talks with the DOJ. Id. ¶ 21. The DOJ gave

Guidehouse a redacted copy of the qui tam complaint, which alleged that Guidehouse had rushed to win the contract with the State of New York, and used outdated soft- ware with inadequate security protections that it hid from New York. Id. ¶¶ 21–23; see also Relator’s Compl. at 13–17. In May 2024, Guidehouse and the DOJ entered into a settlement agreement. Id. ¶ 24; see also R. 1-2, Exh. B, Settlement Agreement. Guidehouse agreed to pay $7.6 million plus interest and the relator’s attorney’s fees

of $50,000. Compl. ¶ 24. The Settlement Agreement sets forth the conduct that it covers, which includes an “information security breach” and use of “unauthorized software.” Settlement Agreement ¶¶ A–K. The Agreement does not make any

2The relator was later revealed to be Elevation 33, LLC. Compl. ¶ 21; Relator’s Compl. at 1. 3 statements or admissions establishing that Guidehouse committed any dishonest, fraudulent, or knowing acts or violations. Compl. ¶¶ 26–27. In August 2024, Guidehouse requested reimbursement from Continental for

the costs of defending and settling the matter with the DOJ. Compl. ¶ 41. Continental denied the claim, arguing that the “gravamen of the Qui Tam Civil Action is that Guidehouse made intentional and deliberate misrepresentations … and, then, know- ingly hid the noncompliance from New York State.” Id. ¶¶ 42–43. According to Con- tinental, this amounted to allegations of fraudulent acts or knowing violations of con- tracts under the meaning of the Deliberate Acts exclusion. Id. ¶ 43. So Guidehouse has now sued Continental for breach of contract, asserting that the qui tam action

and ensuing Settlement were covered under its insurance Policy and demanding that Continental pay the costs of defending the action and indemnify it for the Settlement amount. See generally Compl. II. Legal Standard A district court may “transfer any civil action to any other district or division where it might have been brought” for “the convenience of parties and witnesses, in the interest of justice.” 28 U.S.C. § 1404(a). In deciding whether to transfer venue,

courts consider whether (1) venue is proper in both the transferor and transferee courts; (2) the transferee district would be more convenient for the parties and wit- nesses; and (3) transfer would serve the interest of justice. Gueorguiev v. Max Rave, LLC, 526 F. Supp. 2d 853, 856 (N.D. Ill. 2007). Weighing the factors for and against transfer “necessarily involves a large degree of subtlety and latitude, and, therefore, 4 is committed to the sound discretion of the trial judge.” Coffey v. Van Dorn Iron Works, 796 F.2d 217, 219 (7th Cir. 1986); see id. at 219 n.3 (“[I]t should be noted that the language of § 1404(a) does not indicate the relative weight to be accorded each fac-

tor.”). The party seeking transfer bears the burden of establishing “that the trans- feree forum is clearly more convenient.” Id. at 219–20. III. Analysis Continental asserts that venue is proper in both this District and in the pro- posed transferee district. Def.’s Mot. at 3–4. Guidehouse does not dispute this. R. 26, Pl.’s Resp. at 7 n.4.3 The Court agrees that venue is proper in both districts under 28 U.S.C.

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