Key Takeaways
- Unum Life Insurance Company of America attempted to transfer a Florida ERISA disability benefits lawsuit to Utah, arguing that venue there was more convenient.
- The Court found the request untimely because Unum waited until the discovery period was nearly complete before seeking transfer.
- The judge emphasized that ERISA cases are often resolved on the papers, making convenience arguments less persuasive.
- This case highlights how Dabdoub Law Firm can help claimants fight major insurers like Unum across the country by making strong legal arguments agsint insurers’ tactics.
Background of the Case
MiKalley Williams filed an ERISA lawsuit against Unum Life Insurance Company of America in the Southern District of Florida in October 2024, seeking long-term disability benefits. Ms. Williams resides in Utah and received the majority of her medical treatment there. Ms. Williams did not receive any medical treatment in Florida.
After nearly seven months of litigation, Unum moved to transfer the case to the District of Utah. Its reasoning was largely strategic because Utah falls under the Tenth Circuit, which has stricter rules on what evidence can be considered in ERISA disability cases. By contrast, the Eleventh Circuit, which governs Florida cases, allows courts to consider certain evidence outside of the insurance company’s claim file, a rule that often benefits claimants.
Unum filed its transfer request just one week before discovery was scheduled to close and only three weeks before the pretrial motions deadline. The Court denied the motion, finding that Unum’s timing and motivations weighed against transfer.
Legal Standard for Transfer of Venue
Under Federal rules, a federal court may transfer a case to another district for the convenience of the parties and witnesses and in the interest of justice. Courts typically analyze several factors, including:
- Convenience of witnesses and parties;
- Location of relevant documents and access to evidence;
- Locus of operative facts;
- Plaintiff’s choice of forum; and
- Interests of justice and efficiency.
Why the Court Rejected Unum’s Motion
Timeliness of the Request
The most important factor in this case was timing. The Court found Unum did not act with “reasonable promptness” because it waited until the end of the discovery period, and just three weeks before the pretrial motion deadline, to seek transfer. The Court noted that Unum likely sought transfer only after realizing that newly produced documents outside the administrative record could be used against it in the Eleventh Circuit, but would be excluded in the Tenth Circuit.
Convenience Factors Had Little Weight
Because ERISA cases resemble appeals more than traditional trials, arguments concerning the convenience for witnesses or access to documents carried little significance. The Court emphasized that ERISA disability insurance cases are typically resolved on motions, not through witness testimony or trials.
Plaintiff’s Choice of Forum
While the Southern District of Florida did not have a strong connection to the operative facts, the Court gave weight to Ms. Williams’s choice to file in Florida. Courts are generally reluctant to override a plaintiff’s forum selection unless the balance of factors strongly favors the defendant.
Interests of Justice
The Court stressed that transferring the case at this late stage would cause unnecessary delay and waste resources, undermining the very purpose of § 1404(a). Allowing Unum to move the case at the eleventh hour would be unfair to Ms. Williams, who had already litigated for months under the Florida court’s schedule.
What This Means for Disability Claimants
This ruling highlights several important points for people fighting long term disability insurance denials:
- Disability insurance companies often try to gain an advantage by shifting cases to more favorable jurisdictions. Courts, however, will scrutinize these tactics, especially if the request comes late in the litigation.
- ERISA litigation is largely a battle over the administrative record. Courts generally resolve long term disability cases through written motions, so arguments about witness convenience or trial logistics rarely carry much weight.
- The choice of forum can have a major impact. Different federal circuits apply different evidentiary rules in ERISA cases, which can significantly affect the outcome of a claim.
How Dabdoub Law Firm Can Help
At Dabdoub Law Firm, we focus exclusively on disability insurance and life insurance claims. We have taken on every major insurance company, including Unum, and we know the tactics they use to avoid paying benefits. Our Firm:
- Represents clients nationwide, in every federal circuit.
- Has a proven track record of success in federal court.
- Is a litigation powerhouse dedicated to disability and life insurance law.
For claimants, this means you have experienced attorneys who understand the nuances of ERISA law and how to counter insurer strategies—whether the fight is about venue, evidentiary rules, or the merits of your claim.
Conclusion
The ruling in Williams v. Unum Life Insurance Company of America sends a clear message to insurance companies: venue transfer motions must be timely and cannot be used as a last-minute strategy to shift the law in the insurer’s favor. For disability claimants, it underscores why experienced legal representation is critical. Insurers like Unum know the system well, but so do we.
If you’re dealing with a denied or terminated LTD claim, especially against Unum, contact Dabdoub Law Firm. This is all we do, and we know how to win.
Disclaimer: Dabdoub Law Firm did not handle this case.