Judge: Michael P. Linfield, Case: 21STCV42265, Date: 2022-09-28 Tentative Ruling

Case Number: 21STCV42265    Hearing Date: September 28, 2022    Dept: 34

SUBJECT:                 Motion to Stay or Dismiss Action Based on Forum Non Conveniens

Moving Party:          Defendant Global Reinsurance Corporation of America (“Global”)

Resp. Party:             Plaintiff Pacific Employers Insurance Company (“Pacific”)

 

 

Defendant Global Reinsurance Corporation of America’s Motion to Stay or Dismiss Action Based on Forum Non Conveniens is GRANTED. The action is DISMISSED.

 

I.           BACKGROUND

 

On November 16, 2021, Plaintiff Pacific Employers Insurance Company filed a complaint against Defendant Global Reinsurance Corporation of America alleging the following causes of action:

 

1.           Breach of Contract

2.           Declaratory Relief as to the Facultative Certificate

 

On November 18, 2021, Plaintiff Pacific Employers Insurance Company filed a First Amended Complaint against Defendant Global Reinsurance Corporation of America alleging the following causes of action:

 

1.           Breach of Contract

2.           Declaratory Relief as to the Facultative Certificate

 

On August 9, 2022, Defendant Global Reinsurance Corporation of America (“Global”) moved the Court “for an order dismissing this action or, in the alternative, staying all further proceedings. The motion will be made on the ground that California is an inconvenient forum for trial of this action and in the interest of substantial justice this action should be heard in a forum outside of this State. Code Civ. Proc §§ 418.10(a); 410.30(a).” (Motion, p. 2:1-4.)

 

On September 6, 2022, Plaintiff Pacific Employers Insurance Company (“Pacific”) opposed Global’s motion to stay or dismiss for forum non conveniens.

 

On September 20, 2022, Global replied to Pacific’s opposition.

 

II.        ANALYSIS

 

A.          Request for Judicial Notice

 

On August 9, 2022, Defendant Global Reinsurance Corporation of America requested that the Court take judicial notice of the following documents in support of Global’s Motion to Stay or Dismiss Based on Forum Non Conveniens.

 

1.           Exhibit 1 The Amended Complaint for Damages and Declaratory Relief and Exhibit A thereto filed in the present action styled Pacific Employers Insurance Company v. Global Reinsurance Corporation of America, Case No. 21STCV42265;

2.           Exhibit 2- The first page of the most recent Annual Statement filed by Global with the Pennsylvania Secretary of State which evidences that Global is organized and incorporated under the laws of New York, its principal place of business is in Philadelphia, Pennsylvania and the primary location of its books and records is in Philadelphia, Pennsylvania.

 

Global’s request for judicial notice of Exhibit 1 is DENIED as superfluous. Any party that wishes to draw the Court’s attention to a matter filed in this action may simply cite directly to the document by execution and filing date. (See Cal. Rules of Court, rule 3.1110(d).)

 

The Court GRANTS Global’s request for judicial notice of Exhibit 2 pursuant to Evidence Code § 452(c).

 

B.          Legal Standard

 

A defendant, on or before the last day of his or her time to plead or within any further time that the court may for good cause allow, may serve and file a notice of motion to stay or dismiss the action on the ground of inconvenient forum. (CCP, § 418.10(a)(2). When a court upon motion of a party or its own motion finds that in the interest of substantial justice an action should be heard in a forum outside this state, the court shall stay or dismiss the action in whole or in part on any conditions that may be just. (CCP, § 410.30(a).)

 

"Forum non conveniens is an equitable doctrine invoking the discretionary power of a court to decline to exercise the jurisdiction it has over a transitory cause of action when it believes that the action may be more appropriately and justly tried elsewhere. . . . In determining whether to grant a motion based on forum non conveniens, a court must first determine whether the alternate forum is a “suitable” place for trial. If it is, the next step is to consider the private interests of the litigants and the interests of the public in retaining the action for trial in California. The private interest factors are those that make trial and the enforceability of the ensuing judgment expeditious and relatively inexpensive, such as the ease of access to sources of proof, the cost of obtaining attendance of witnesses, and the availability of compulsory process for attendance of unwilling witnesses. The public interest factors include avoidance of overburdening local courts with congested calendars, protecting the interests of potential jurors so that they are not called upon to decide cases in which the local community has little concern, and weighing the competing interests of California and the alternate jurisdiction in the litigation." (Stangvik v. Shiley Inc. (1991) 54 Cal.3d 744, 751 [cleaned up].)

 

“An alternative forum is “suitable” if it has jurisdiction and an action in that forum will not be barred by the statute of limitations.” (C. Forum Non Conveniens, Cal. Prac. Guide Civ. Pro. Before Trial Ch. 3-C; Guimei v. General Elec. Co. (2009) 172 CA4th 689, 696, 91 CR3d 178, 185; Chong v. Sup.Ct. (HBZ Finance Ltd.) (1997) 58 CA4th 1032, 1036-1037.)

 

"On a motion for forum non conveniens defendant, as the moving party, bears the burden of proof. The granting or denial of such a motion is within the trial court's discretion, and substantial deference is accorded its determination in this regard." (Id.) A nonresident plaintiff "who files suit in California is entitled to due deference under the circumstances presented, not a strong presumption, in favor of its choice of forum. That deference is to be weighed and balanced by the trial court along with all the other pertinent factors, including the defendant's residence or principal place of business, and has no direct bearing on the moving defendant's burden of proof." (National Football League v. Fireman's Fund Ins. Co. (2013) 216 Cal.App.4th 902, 929.)

 

The court's ruling on a forum non conveniens motion may turn on whether dismissal, or only a stay, is sought. If a stay is granted, the California court retains jurisdiction, so that if for any reason plaintiff is denied a prompt trial in the alternative forum, the California court can order the action resumed in California. On the other hand, once a dismissal is ordered, the California court loses jurisdiction and there is nothing left to resume. For this reason, the court's power to dismiss an action for inconvenient forum is more limited than its power to stay. (C. Forum Non Conveniens, Cal. Prac. Guide Civ. Pro. Before Trial Ch. 3-C; Archibald v. Cinerama Hotels (1976) 15 Cal.3d 853, 858-859.)

 

C.          Discussion

 

1.           Timeliness

 

Pacific argues that Global’s motion is untimely under CCP § 418.10(b) because Global made a general appearance in the case and waited nine months while availing itself of California courts before filing the present motion. (Opposition, MPA, 4:3—6:23.)

 

However, a defendant may, not must, serve and file a motion to stay or dismiss based on inconvenient forum within the timing framework of CCP § 418.10(a). There is no time limit for filing a motion to stay or dismiss based on inconvenient forum and filing such a motion one year after a case is filed may be permissible, especially when no prejudice to a plaintiff is found. (Morris v. AGFA Corp. (2006) 144 Cal.App.4th 1452, 1461.)

 

The Court does not find evidence to suggest that granting the present motion would prejudice Pacific. Discovery between the parties only recently began. (Dubner Decl., ¶ 10; Tabb Decl. (Reply), ¶ 6.) Thus, the Court finds that the present motion is timely under Morris.

 

2.           Suitability of Alternative Forum

 

Global argues that the suitability requirement for stay or dismissal based on forum non conveniens is satisfied by the Commonwealth of Pennsylvania because (1) a Pennsylvania state court may exercise personal jurisdiction or Pacific and Global because Pacific is a Pennsylvania corporation, both parties have their principal place of business in Pennsylvania, and Global has significant contacts with the alternative forum, (2) the statute of limitations on written contract actions has not run in Pennsylvania, and (3) Pennsylvania law recognizes facultative reinsurance contract causes of action.  (Motion, MPA, p. 10:5-23.)

 

The Court finds no evidence that Pennsylvania is an unsuitable forum.

 

3.           Private Interest Factors

 

Global notes the following:

 

1)          Both parties reside in Pennsylvania, not California. (Motion, MPA, p. 11:10-16, First Amended Complaint, ¶ 1; Request for Judicial Notice, p. 2:9-12, Ex. 2.)

2)          Relevant witnesses reside and/or work outside California. (Motion, MPA, p. 11:17-27; Reinsel Decl., ¶ 2; Burke Decl., ¶3; Brandt Decl., ¶¶ 3, 5, Ex. 5.)

3)          Global’s documents “are maintained in Pennsylvania and Global’s business records related to the issuance of the Certificate are located in New York.” (Request for Judicial Notice, p. 2:9-12, Ex. 2; Brandt Decl., ¶ 4.)

4)          Relevant events to the action occurred outside California. (Motion, MPA, p. 12:8-21; Burke Decl., ¶¶ 2-4, Ex. 4; Reinsel Decl., ¶¶ 3-5, Ex. 3; Brandt Decl., ¶¶ 2-8, Exs. 5-8.)

 

Pacific argues that Global did not specify whether two of its identified witnesses are within Pennsylvania state courts’ subpoena power. (Opposition, p. 7:21-22.) Pacific notes that technological advances should render the physical location of Global’s relevant documents mainly irrelevant. (Opposition, p. 7:23—8:10.) Pacific also notes that the facultative reinsurance certificate “was placed by a California broker for a California insurer with a New York-based reinsurer; as a result, that factor favors California.” (Opposition, p. 8:6-7.)

 

4.           Public Interest Factors

 

Global notes that Pacific is not a California corporation and has not resided in California for twenty years. (Motion, MPA, p. 13:3-4, 14:9.) Global argues that public interest factors favor the motion given overburdened California court dockets given the ongoing COVID-19 pandemic, and low Californian interest “in litigating a dispute brought by a corporation that has not been a California resident in more than 20 years, seeking reinsurance under a contract issued decades ago for underlying asbestos lawsuits that were filed nationwide where only 1.5% of those lawsuits were filed in California.” (Motion, MPA, p. 14:8-11.) Pacific notes that state court calendars were affected by COVID-19 universally and that Global presents no evidence that Pennsylvania’s courts endure less calendar overcrowding than California’s. (Opposition, p. 8:23-25.) Pacific notes further “California’s strong public interest in assuring that reinsurance proceeds are available for a policy issued by a California insurer to a California insured.” (Opposition, p. 9:5-6.)

 

5.           Conclusion

 

The Court finds that the parties’ residences, the residences of relevant witnesses, the location of relevant events to the present action weigh in favor of the present motion. (The Court does not find Global’s argument about the COVID-19 pandemic to be persuasive; the pandemic has affected all courts throughout the country.) This case involves litigating the responsibilities of two foreign corporations under a decades-old contract for underlying lawsuits mostly filed outside California.

 

Pennsylvania is a suitable – and less costly – forum. Since the Statute of Limitations in Pennsylvania has not run, this case can be filed in that foreign jurisdiction.

 

 

 

III.     CONCLUSION

 

Defendant Global Reinsurance Corporation of America’s Motion to Stay or Dismiss Action Based on Forum Non Conveniens is GRANTED. The action is DISMISSED.