Layfield v. Unum Life Insurance Company of America

District Court, N.D. California·Decided May 9, 2025·No. 3:24-cv-03616·Unknown

Opinion

JENNIFER LAYFIELD, Case No. 24-cv-03616-AMO

Plaintiff, ORDER GRANTING MOTION TO v. TRANSFER

UNUM LIFE INSURANCE COMPANY Re: Dkt. No. 23 OF AMERICA, Defendant.

This is an Employee Retirement Insurance Security Act of 1974 (“ERISA”), 29 U.S.C. §§ 1001 et seq., action for long term disability (“LTD”) benefits under an employee benefit plan. Defendant Unum Life Insurance Company of America (“Unum”) moves to transfer the case to the Central District of California under Title 28 U.S.C. § 1404 for the convenience of the parties. Unum’s motion to transfer was heard before this Court on April 24, 2025. Having read the papers filed by the parties and carefully considered their arguments therein and those made at the hearing, as well as the relevant legal authority, the Court hereby GRANTS the motion to transfer for the following reasons. Plaintiff Jennifer Layfield is an attorney who most recently worked for DLA Piper, LLP. Compl. (ECF 1) ¶ 2. Layfield resides in Pacific Palisades in the Central District of California, and she was the only person in her practice team based in DLA Piper’s Century City offices near her home. See Bell Decl., Ex. A at -66 (ECF 23-5 at 3); Layfield Decl. (ECF 30-1) ¶¶ 2, 11. The rest of Layfield’s work team were based in DLA Piper’s San Francisco office and the majority of her clients were based in the San Francisco Bay Area, making her work largely remote. Layfield Piper is headquartered in Maryland. Bell Decl., Ex. A at -165 (ECF 23-5 at 17). Defendant Unum is based in Maine. Compl. ¶ 3. In December 2020, Layfield contracted COVID-19. Layfield Decl. ¶ 13. It developed into long-COVID, preventing her from returning to work full-time. Id. ¶¶ 14-16. All the physicians Layfield consulted were located in Los Angeles. See generally Bell Decl., Ex. A. Layfield submitted an LTD benefits claim to Unum under DLA Piper’s LTD plan. Layfield Decl. ¶ 17. Unum denied her claim. Id. That claim denial is the subject of the instant suit. ERISA specifically provides that civil actions “may be brought in the 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). Layfield argues, based on this provision, that venue is proper here because Unum can be “found” in this district. Opp. at 4 (citing Varsic v. U.S. Dist. Court for Cent. Dist. of California, 607 F.2d 245, 247 (9th Cir. 1979)). Unum concedes that venue is proper in this district, but still contends that the case should be transferred. See Mot. at 5. A motion to transfer an action to another district under Title 28 U.S.C. § 1404(a) lies within the district court’s broad discretion and must be determined on an individualized basis. Jones v. GNC Franchising, Inc., 211 F.3d 495, 498 (9th Cir. 2000). “Section 1404(a) requires the court to make a threshold determination of whether the case could have been brought where the transfer is sought. If venue is appropriate in the alternative venue, the court must weigh the convenience of the parties, the convenience of the witnesses, and the interest of justice.” State v. Bureau of Land Mgmt., 286 F. Supp. 3d 1054, 1059 (N.D. Cal. 2018). The moving party must make a “strong showing of inconvenience to warrant upsetting the plaintiff’s choice of forum” by showing private factors relating to “the convenience of parties and witnesses” and public factors relating to “the interest of justice” warrant transfer. Decker Coal Co. v. Commonwealth Edison Co., 805 F.2d 834, 843 (9th Cir. 1986). The public and private factors courts should consider include:

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Layfield v. Unum Life Insurance Company of America, (N.D. Cal. 2025).

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