Indiana GRQ, LLC v. American Guarantee and Liability Insurance Company, 3:21-cv-00227

Indiana GRQ, LLC (a Delaware LLC headquartered in Indiana) sued seven insurers in Ohio state court over disputed property-insurance coverage for a loss at its sole asset: a plant at 701 Chippewa Ave., South Bend, Indiana (the "Plant"). The case was removed to federal court and defendants moved to transfer to the N.D. of Indiana.
The loss: on August 15, 2016 water inundated underground electrical vaults, destroying switchgear, transformers, and related equipment and causing PCB, oil, water, and asbestos contamination; Indiana GRQ alleges insurers underpaid and refused full remediation and restoration costs.
Indiana GRQ paid its $1 million deductible; insurers paid >$2.6 million but dispute remaining obligations (remediation and restoration costs potentially in the millions).
Indiana GRQ’s managing company, non-party IRG, has an office in Richfield, Ohio and manages the Plant; IRG also has other offices (including Larchmont, NY). IRG’s Ohio office is the only meaningful Ohio tie to the dispute.
Defendants argued (and the court found) that the Plant, the bulk of evidence, and most witnesses (including state environmental officials) are in Indiana; remedial work and related documents are located in or relate to Indiana.
The court concluded public- and private-interest factors under 28 U.S.C. § 1404(a) favor transfer to the Northern District of Indiana and granted the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether transfer under 28 U.S.C. §1404(a) is warranted	Ohio is proper because IRG (managing company) conducts claim handling from Ohio and the policy was procured in Ohio	Transfer to Indiana is proper because the Plant, most witnesses, and evidence are in Indiana	Transfer granted: Indiana is superior forum
Weight of plaintiff's chosen forum (forum deference)	Indiana GRQ chose Ohio; its choice should be given deference	Plaintiff is not Ohio "home"; only tenuous Ohio contacts via non-party IRG	Little weight given to Ohio choice because plaintiff is not based there; favors transfer
Private-interest factors (witnesses, proof, view of premises)	Some claim-handling and records are in Ohio; insurers adjusted via multiple states	Majority of percipient witnesses (contractors, IDEM, remediation experts) and proof are in Indiana; a jury view may be needed	Private factors favor transfer (witness/evidence location predominates)
Public-interest factors (local interest, administering law, jury pool)	Dispute is contract interpretation; Ohio has interest due to IRG presence	Indiana has strongest interest because remediation and environmental oversight concern Indiana soil, water, and agencies	Public-interest factors weigh strongly for transfer to Indiana

Continental Grain Co. v. The FBL-585, 364 U.S. 19 (U.S. 1960) (transfer statute purpose: convenience of parties and witnesses)
Van Dusen v. Barrack, 376 U.S. 612 (U.S. 1964) (transfer should not merely shift inconvenience)
Stewart Org., Inc. v. Ricoh Corp., 487 U.S. 22 (U.S. 1988) (case-by-case transfer analysis)
Atlantic Marine Constr. Co. v. U.S. Dist. Court for W. Dist. of Tex., 571 U.S. 49 (U.S. 2013) (private- and public-interest factors guide §1404(a) analysis)
Piper Aircraft Co. v. Reyno, 454 U.S. 235 (U.S. 1981) (enumeration of private- and public-interest factors)
Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (U.S. 1947) (local interest in having localized controversies decided at home)
Zions First Nat’l Bank v. Moto Diesel Mexicana, S.A. de C.V., 629 F.3d 520 (6th Cir. 2010) (weight of plaintiff's forum choice reduced when forum is not plaintiff's home)
Reese v. CNH Am. LLC, 574 F.3d 315 (6th Cir. 2009) (district court has broad discretion on transfer)
Norwood v. Kirkpatrick, 349 U.S. 29 (U.S. 1955) (forum non conveniens and related venue principles)
Stewart v. Dow Chem. Co., 865 F.2d 103 (6th Cir. 1989) (no single factor is determinative in transfer analysis)