Location, Location, Location. Washington Federal Court Looks To Where Benefit Plan Was Signed And Negotiated In Agreeing To Transfer ERISA Class Action To Georgia

Much like buying a home, location can mean everything when defending a class action. Therefore, it is common for defendants to try and transfer class actions to what is viewed as a more favorable jurisdiction when there is at least a significant connection with that forum. When this happens, courts apply a largely predictable set of factors and considerations in deciding the motion. Perhaps it should come as no surprise that these factors become a little less intuitive when trying to transfer an ERISA class action, at least according to the recent decision in Mayfield v. ACE American Ins. Co., 18-cv-1695 (W.D. Wash. May 13, 2019).

In Mayfield, the plaintiff was a participant in his employer's welfare benefit plan, which included accidental death and dismemberment ("AD&D") insurance. ACE insured the plan's AD&D benefit. The plaintiff filed a putative ERISA class action lawsuit against ACE in the Western District of Washington, claiming he and others did not receive full insurance proceeds upon the death of covered individuals. ACE moved to transfer the case to the Northern District of Georgia, originally arguing that Georgia was a more convenient forum because more putative class members were in Georgia than Washington, the plan was administered in Georgia, and ACE had some...