Smith v. Walgreens Co.

Illinois Appellate Court
Civil Court
Forum Non Conveniens
Citation
Case Number: 
2024 IL App (5th) 240394
Decision Date: 
Tuesday, December 24, 2024
District: 
5th Dist.
Division/County: 
St. Clair Co.
Holding: 
Reversed and remanded.
Justice: 
SHOLAR

Defendant appealed from a circuit court order denying its motion to transfer pursuant to the doctrine of forum non conveniens. The appellate court reversed and remanded, finding that the weight of the private interest factors, including the ease of access to witnesses and sources of evidence, favored transfer and that the public interest factors strongly favored that the case be transferred Christian County. The court further explained that its deference to plaintiff’s chosen forum was reduced because she did not reside there and the action did not arise there. (BOIE and VAUGHAN, concurring)