On June 6, 2025, the United States District Court for the Eastern District of Pennsylvania granted a Motion to Transfer Woodward v. General Motors, LLC, 2025 U.S. Dist. Lexis 108258, 2025 WL 1616795 (E.D. Pa. June 6, 2025), to the United States District Court for the Middle District of Pennsylvania, after finding that (a) there was no connection to the Eastern District and (b) the plaintiff offered no good reason for the case to remain in the Eastern District. In a published memorandum, the Court provides an analysis of both public and private interest factors considered when determining whether a transfer to a different venue is appropriate.
The matter concerns a motor vehicle accident on Route 6, in Tioga County, Pennsylvania, which resulted in Christine Woodward being pinned in her 2013 GMC Acadia and burning to death. The plaintiff, Mason Woodward, individually and as Administrator of his mother’s estate, filed suit in the Eastern District, alleging that the vehicle was not crashworthy and asserting claims of strict products liability, breach of warranty, and negligence. One of the defendants, General Motors, LLC (“GM”), filed a motion to transfer the case to the Middle District, pursuant to 28 U.S.C. § 1404(a), as the more proper venue.
There are three factors listed in 28 U.S.C. § 1404(a) for a court to consider when determining whether transfer is appropriate: convenience of parties, convenience of witnesses, and interest in justice. However, there are also private and public interest factors used “to determine whether on balance the litigation would more conveniently proceed and the interests be better served by transfer to a different forum.” Jumara v. State Farm Ins. Co., 55 F.3d 873, 879 (3d Cir. 1995). In total, the court analyzed the six private interest factors from In re McGraw-Hill Educ. Holdings LLC, 909 F.3d 48, 57 (3d Cir. 2018), and the six public interest factors from Jumara, 55 F.3d at 879, to determine whether a transfer the case to the Middle District would be appropriate.
Of the twelve total factors, only plaintiff’s forum preference, a private interest factor, weighed against transfer. While a plaintiff’s preference is a paramount consideration, the court noted that the deference given will soften when the plaintiff does not reside in that forum and when there is no significant connection between the forum and the facts giving rise to the case. Here, plaintiff chose the Eastern District because there was a GM distribution facility in Bucks County that potentially may have been involved in the manufacturing of Ms. Woodward’s vehicle. However, none of the parties, including plaintiff, resided in the Eastern District, and nothing relevant occurred in the Eastern District. Plaintiff was unable to provide evidence to support an inference that the Bucks County distribution center had any actual relation to the case and, consequentially, minimal weight was assigned to Mr. Woodward’s choice of forum.
There were two private interest factors that favored transfer: GM’s forum preference and location where the claim arose. GM preferred to litigate in the Middle District because the accident happened in Tioga County, which is in the Middle District, and all the witnesses also resided in the Middle District. GM’s preference received less weight than plaintiff’s, but it was still factored into the analysis. Addressing the location where the claim arose, courts in the Third Circuit have concluded that product liability claims arise where the product operated and the injury occurred. See In re Consol. Parlodel Litig., 22 F. Supp.2d 320, 326 (D.N.J. 1998); Coppola v. Ferrellgas, Inc, 250 F.R.D. 195, 198 (E.D. Pa. 2008). In response to plaintiff arguing that a product liability case concerns design and manufacture, not the accident itself, the court explained that the site of the accident could play a significant role; there are first responders and eyewitnesses that can comment on the state of the vehicle following the crash, the failed efforts to extract the decedent, and her suffering.
The remaining private interest factors of convenience of parties, convenience of witnesses, and the location of books and records were all found to be neutral. Convenience of witnesses is the most important factor in determining whether to transfer to a new venue, but it is only relevant if the chosen forum would cause a witness to be unavailable for trial or would incur substantial travel expenses.
Similarly, all six of the public interest factors were found to be either neutral or favored transfer, to the degree they were relevant, but carried no significant weight. Specifically, the enforceability of the judgement, the fora’s public policies, and the judge’s familiarity with the law were found to be neutral because both districts are in Pennsylvania. Plaintiff provided no evidence, such as the number of cases per judge or the median time to resolution, to show court congestion in competing forum would favor a transfer and, therefore, that factor was assigned no weight. In analyzing practical trial considerations, the court found that the Middle District would be more convenient because of the accident site, relevant evidence, and witnesses. However, due to the close proximity of the districts, in this case they were neighboring districts, that factor was not a strongly weighted. The final factor, the local interest in deciding a controversy at home, did favor the Middle District, as the events occurred within its borders and bore consequences for its residents.
Motions to transfer are not liberally granted, but the Woodward court found that GM met its burden of persuasion when the statutory, public interest, and private interest factors were considered and balanced. In other words, the Eastern District emphasized the numerous factors considered when deciding whether to transfer a case to a different venue on the basis of convenience, while also showing how the moving party is not the only party with a burden of proof to show why the party’s chosen forum is appropriate.
The Woodward Memorandum can be found here.
For additional questions, please contact Conrad James Benedetto, Esq. and/or Steven E. Tambon, Esq.
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