NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in
the limited circumstances allowed under Rule 23(e)(1).
2023 IL App (3d) 220360-U
Order filed July 17, 2023
____________________________________________________________________________
IN THE
APPELLATE COURT OF ILLINOIS
THIRD DISTRICT
2023
PAUL ALAN LARSON and CYNTHIA ) Appeal from the Circuit Court
LARSON, individually and next best friends
) of the 12th Judicial Circuit,
of B.L., a minor, ) Will County, Illinois,
)
Plaintiffs-Appellees, ) Appeal No. 3-22-0360
) Circuit No. 22-LA-75
v. )
)
ILLINOIS CENTRAL SCHOOL BUS, LLC, ) Honorable
) Roger D. Rickmon,
Defendant-Appellant. ) Judge, Presiding.
___________________________________________________________________________
PRESIDING JUSTICE HOLDRIDGE delivered the judgment of the court.
Justices Brennan and Davenport concurred in the judgment.
____________________________________________________________________________
ORDER
¶1 Held: The circuit court abused its discretion when it denied the defendant’s motion to
dismiss that it brought pursuant to the doctrine of forum non conveniens.
¶2 The plaintiffs, Paul Alan Larson and Cynthia Larson, individually and next best friends of
B.L., a minor, filed a complaint founded in negligence against the defendant, Illinois Central
School Bus, an Illinois limited liability company with its principal place of business in Will
County, for an incident that occurred in Denton County, Texas. The defendant filed a motion to
dismiss pursuant to the doctrine of forum non conveniens, which the circuit court denied. The
defendant filed this interlocutory appeal, which this court allowed.
¶3 I. BACKGROUND
¶4 A. The Complaint
¶5 The plaintiffs filed a complaint founded in negligence against the defendant. The complaint
set forth the following allegations. On the morning of March 22, 2021, a driver and aide, who were
employees of the defendant, picked up B.L. at his home in Denton County, Texas, to transport him
to school. B.L. is a mentally and physically disabled minor. The driver and aide loaded B.L. in his
wheelchair onto the bus and improperly secured the wheelchair. Shortly thereafter, as the bus was
turning, B.L.’s wheelchair turned over, causing him to hit his head and land on his right side. As
a result of the fall, B.L. sustained a concussion and a fractured right elbow. The plaintiffs alleged
the defendant and its agents were guilty of the following acts or omissions: failing to implement
policies and procedures pertaining to safely transporting children (such as B.L.), failing to properly
train drivers and aides regarding properly and safely securing wheelchairs into its buses, failing to
properly secure B.L.’s wheelchair into the bus, failing to adequately inspect the manner in which
B.L.’s wheelchair was secured to the bus, failing to correct the dangerous condition created by
improperly securing B.L.’s wheelchair, failing to properly monitor B.L. and his wheelchair during
the ride to school, creating a dangerous condition on the school bus, and failing to act as a
reasonably prudent owner and/or operator who transports minor disabled children in wheelchairs.
¶6 B. Forum Non Conveniens
¶7 The defendant filed its answer and a motion to dismiss pursuant to the doctrine of forum
non conveniens. The defendant argued that the lawsuit should be dismissed and filed in Texas
because (1) the incident occurred in Denton County, Texas; (2) nearly all of the occurrence
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witnesses and documentary evidence were in Texas; (3) the entirety of the post-accident
investigation and nearly all of B.L.’s post-accident medical treatment occurred in Texas; (4) none
of the investigators, post-accident medical providers, or witnesses were amenable to process by an
Illinois court; (5) it would be costly and inconvenient to secure the attendance of willing witnesses
that are principally located in Texas; and (6) Denton County’s docket was significantly less
congested than Will County’s docket.
¶8 The defendant set forth four categories of witnesses: (1) the plaintiffs, who resided in Texas
with B.L. and their three other children; (2) employee witnesses located in Texas, such as the bus
driver and aide, the bus driver’s immediate supervisor, the dispatcher, and managers who
conducted a post-incident investigation (some of these employee witnesses were employed at the
time of the incident but were no longer employees at the time the case was filed); (3) post-
occurrence witnesses from B.L.’s school who were present at the scene after the incident, which
included the assistant principal, a nurse, the resources officer, and a teacher, who all resided in
Texas; and (4) 13 medical witnesses who treated B.L., 11 of which were located in Texas, 1 in
Virginia (which may have just been a supplies provider), and 1 in Utah.
¶9 The defendant included an affidavit of Richard Price, its Director of Safety, Training, and
Risk Management. He stated that he was familiar with the incident involving B.L. The bus driver,
aide, dispatcher, and supervisors who investigated the incident resided in Texas. The bus driver
and aide received orientation at the defendant’s Denton facility in Lewisville, Texas. The bus
driver and aide’s physical employment and training records were maintained at the Denton facility
and were maintained on its online repository accessible throughout the United States. He also noted
that, for at least one year before and after the incident, the bus involved was regularly inspected
and maintained at the defendant’s Denton facility, which also maintained those records.
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¶ 10 The plaintiffs responded to the defendant’s motion, arguing that the court should deny it
because (1) there were material witnesses in Will County and states other than Texas; (2) the
defendant failed to show that Denton County was a more convenient forum for both parties; (3)
Will County had a substantial interest in this controversy because its resident is the sole defendant;
(4) the motion failed to meet requirements set forth by the supreme court; and (5) the motion was
premature as very limited discovery had taken place. The plaintiffs emphasized that the
defendant’s headquarters and its directors were located in Will County.
¶ 11 C. The Circuit Court’s Ruling
¶ 12 The court held a hearing on the motion. First, it addressed the private interest factors. It
noted that the defendant had its principal place of business in Will County, so any inconvenience,
would be suffered by the plaintiffs who chose this forum. For ease of access to evidence, the court
stated there was no problem obtaining document evidence, such as medical records. As to
witnesses, the court acknowledged that, while it was true that most of the witnesses were located
in Texas, COVID-19 demonstrated that witnesses’ testimony both for discovery and trial could be
obtained through live video platforms. However, the court said this factor slightly favored
dismissal. 1 The court also found that the availability of a compulsory process to compel witnesses
to appear would also favor dismissal. The court noted the cost to obtain witnesses in person but
stated that most of the defendant’s witnesses were in Will County, so that factor was neutral. The
court found access to the location of the occurrence for review not to be relevant in a personal
injury case. The court stated that all practical considerations did not favor either option.
1
The circuit court referred to the motion in this case as a request for a “transfer” rather than a
“dismissal.” Forum non conveniens applies when the alternative forum is another Illinois county (intrastate)
and when the forum is outside of Illinois (interstate). Intrastate forum non conveniens is granted by transfer
order while interstate forum non conveniens is granted by dismissal order. To avoid any confusion, we use
language relating to a dismissal throughout as we are presented with interstate forum non conveniens. See
Ill. S. Ct. R. 187(c)(2) (Jan. 1, 2018).
4
¶ 13 The court also discussed the public interest factors. It stated that the accident took place in
Texas, so there was an interest in having the controversy decided locally, which favored dismissal.
As to the unfairness of imposing a burden of jury duty on the residents of Will County, the court
highlighted that the defendant was incorporated in Illinois, and Will County residents might want
to hear about the incident with alleged negligence in transporting special needs children. Last, the
court considered the administrative difficulty. The court stated that 103% of civil cases filed in
Denton County were resolved last year compared to 100.6% in Will County, which was a
miniscule difference favoring denying the dismissal.
¶ 14 The court stated it considered the factors, gave some deference to the plaintiffs’ choice of
forum, and denied the motion. The defendant filed an interlocutory appeal by permission pursuant
to Illinois Supreme Court Rule 306(a)(2) (eff. Oct. 1, 2020), which this court allowed.
¶ 15 II. ANALYSIS
¶ 16 The doctrine of forum non conveniens assumes that there is more than one forum with the
power to hear the case. Fennell v. Illinois Central Railroad Co., 2012 IL 113812, ¶ 12. Thus, the
doctrine allows a court to decline jurisdiction of a case, even though it may have proper jurisdiction
over the parties and subject matter, if it appears that another forum can better serve the convenience
of the parties and the ends of justice. Id. “Forum non conveniens is a doctrine that is founded in
considerations of fundamental fairness and sensible and effective judicial administration.”
(Internal quotation marks omitted.) Vinson v. Allstate, 144 Ill. 2d 306, 310 (1991).
¶ 17 When considering a forum non conveniens motion, the court balances the relevant public
interest and private interest factors. Tabirta v. Cummings, 2020 IL 124798, ¶ 18. The court must
consider all of the relevant factors, without emphasizing one factor, within the context of the
unique facts of the case. Langenhorst v. Norfolk Southern Railway Co., 219 Ill. 2d 430, 443 (2006).
5
The determination of a forum non conveniens motion lies within the sound discretion of the circuit
court. Fennell, 2012 IL 113812, ¶ 21. This court will only reverse if it can be shown that the circuit
court abused its discretion in balancing the relevant factors. Id. An abuse of discretion will be
found where no reasonable person would take the view adopted by the circuit court. Id.
¶ 18 A. The Plaintiffs’ Choice of Forum
¶ 19 Plaintiffs have a substantial interest in choosing the forum where their rights will be
vindicated, and such choice should rarely be distributed unless the other factors strongly favor
dismissal. Langenhorst, 219 Ill. 2d at 442. However, a plaintiff’s interest in choosing the forum
receives somewhat less deference when neither the plaintiff’s residence nor the site of the accident
or injury is located in the chosen forum. Id. at 442-43. Here, the circuit court stated that it gave
some deference to the plaintiffs’ choice of forum. The plaintiffs argue the court acted within its
discretion by according some deference. We agree.
¶ 20 B. Private Interest Factors
¶ 21 The private interest factors include: (1) the convenience of the parties; (2) the relative ease
of access of sources of testimonial, documentary, and real evidence; (3) the availability of
compulsory process to secure attendance of unwilling witnesses; (4) the cost to obtain attendance
of willing witnesses; (5) the possibility of viewing the premises, if appropriate; and (6) all other
practical considerations that make trial of a case easy, expeditious, and inexpensive. Fennell, 2012
IL 113812, ¶ 15.
¶ 22 1. Convenience of the Parties
¶ 23 The circuit court found that the convenience of the parties favored keeping the case in Will
County because the defendant had its principal place of business there and any inconvenience
would be suffered by the plaintiffs. First, while the location of the defendant’s headquarters is a
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factor to consider, it is not dispositive. See Hansen-Runge v. Illinois Central Railroad Co., 2020
IL App (1st) 190383, ¶ 32. We must look beyond the criterion of venue because a motion pursuant
to the doctrine of forum non conveniens already assumes that the court has jurisdiction over the
defendant. Gridley v. State Farm Mutual Automobile Insurance Co., 217 Ill. 2d 158, 172-73
(2005). The place of the defendant’s residence must be considered along with other connections
that exist between the litigation and the chosen forum. Jones v. Searle Laboratories, 93 Ill. 2d 366,
376-77 (1982). Second, we do not consider any inconvenience to the plaintiff with respect to their
chosen forum. First American Bank v. Guerine, 198 Ill. 2d 511, 518 (2002).
¶ 24 As to convenience of the parties, the defendant argues within the context of the potential
witnesses in this case. In sum, the defendant argues that its critical witnesses are in Texas (supra
¶ 8), while the plaintiffs argue that their critical witnesses are located in Illinois (supra ¶ 10). The
parties essentially dispute whether the action is primarily about alleged negligence of the
defendant’s directors in Illinois or the defendant’s employees in Texas. The plaintiffs specifically
argue the directors’ relevance in that they made decisions regarding training and safety policies
and practices. The defendant contends this claim, as it relates to its directors, is speculative because
there was no evidence indicating that its directors in Illinois could testify as to nationwide safety
policies or safety enhancement implementation. 2 See Hansen-Runge, 2020 IL App (1st) 190383,
¶¶ 20, 33 (finding that the plaintiff’s allegation that decision making at headquarters might have
led to his injuries was pure speculation where there was no evidence to support this contention);
but see Koss Corp. v. Sachdeva, 2012 IL App (1st) 120379, ¶ 101 (the plaintiff’s complaint
included a litany of allegations against the defendant’s corporate policies and training and
2
The parties go so far as to argue the meaning of the word “implement” in the plaintiffs’ complaint
wherein they alleged that the defendant failed “to implement policies and procedures pertaining to safely
transporting children” and whether that applies to the directors. We do not find it necessary to address this
contention as it has no bearing on our analysis.
7
described the relevance of corporate personnel who may be called to testify); Erwin v. Motorola,
Inc., 408 Ill. App. 3d 261, 278-279 (2011) (testimony of corporate officers in Illinois was relevant
to injuries that took place in Texas and Arizona because the corporate officers created policies that
affected working conditions).
¶ 25 Here, the plaintiffs’ allegations were directed at the defendant’s agents and employees. The
complaint did not specifically state that the defendant’s directors created or failed to create policies
and procedures or that they could testify as to the specific policies in Texas and their
implementation. The plaintiffs failed to seek leave for discovery to support their allegation of
corporate decision making, which was allowed per Illinois Supreme Court Rule 187(b) (eff. Jan.
1, 2018). On the other hand, the affidavit of the defendant’s Director of Safety, Training, and Risk
Management did not state that he could not provide testimony relating to these policies and
procedures. Instead, he provided the location of where the incident and training occurred, where
the records were maintained, and where the bus was maintained. Regardless, even if we assume
the allegations as to the defendant’s directors were sufficient, the convenience of the parties still
lends toward dismissal. Further, even if the case comes down to the defendant’s corporate policies,
the importance of the Texas witnesses (incident, post-incident, and medical) is irrefutable in a
negligence case. Thus, Texas is the convenient forum despite the defendant’s two named directors
at its headquarters located in Will County.
¶ 26 2. Ease of Access to Evidence
¶ 27 We next consider ease of access to sources of testimonial, documentary, and real evidence.
The circuit court found there was no issue with obtaining documentary evidence, such as medical
records. It is true that the location of relevant documents deserves little weight when these
documents can be copied and sent relatively easily and inexpensively. Fennell, 2012 IL 113812, ¶
8
36. The court also found that recent history demonstrated that witness testimony can be obtained
through live video platforms. However, the court still found that ease of access to evidence slightly
favored dismissal as most of the witnesses were in Texas.
¶ 28 The defendant argues that the court in effect improperly eliminated access to testimonial
evidence as a private interest factor. The defendant explains, that while electronic documents may
be an adequate substitute for paper records, Illinois courts have long recognized there is no
adequate substitute for live testimony in court at trial. We agree with the defendant that remote
testimony is not the norm, but rather, the exception. 3 Here, the vast majority of witnesses are
located in Texas, and the ease of access to these individuals lends to Denton County instead of
Will County (approximately 900 miles away). We also note none of B.L.’s medical treatment
occurred in Illinois. Thus, as the circuit court found, ease of access to evidence favors dismissal.
¶ 29 3. Availability of Compulsory Process
¶ 30 The next factor is the availability of compulsory process to secure attendance of unwilling
witnesses. Here, the court found this factor favored dismissal. We agree. The plaintiffs disagree
and argue this factor is neutral because, where a defendant’s employees reside in both states, one
forum is not favored over another (citing Koss, 2012 IL App (1st) 120379, ¶ 127). However, this
argument oversimplifies the witnesses in this case. The two directors, the only witnesses named
by the plaintiffs in Will County, are available as employees of the defendant regardless of whether
the case is tried in Illinois or Texas. See Illinois Tool Works v. Sierracin Corp., 134 Ill. App. 3d
63, 68 (1985); W.R. Grace & Co. v. Beker Industries, Inc., 128 Ill. App. 3d 215, 221 (1984). The
3
During the pendency of this appeal, Illinois Supreme Court Rules 45 and 241 were amended,
which permit remote testimony where good cause is shown and prior approval is obtained from the judge
presiding over the matter and appropriate safeguards are in place. Ill. S. Ct. Rs. 45(c), 241(a)-(b) (eff. Feb.
2, 2023). The committee comments to Rule 241 reaffirms the significance of in-person testimony: “[t]he
presentation of in-person testimony remains of utmost importance in trials and evidentiary hearings
described in Rule 45(c)(1).” Ill. S. Ct. R. 241, Committee Comments (rev. Feb. 2, 2023).
9
same cannot be said for the witnesses that are no longer employees of the defendant and the
majority of witnesses who reside in Texas. See Gridley, 217 Ill. 2d at 174 (Illinois courts do not
have subpoena power in other states).
¶ 31 4. Cost to Obtain Attendance of Willing Witnesses
¶ 32 We also consider the cost to obtain attendance of willing witnesses. The court noted the
cost to obtain witnesses in person, but found the factor to be neutral, as most of the defendant’s
witnesses were in Will County. It is unclear why the court focused on the two directors without
considering the vast majority of witnesses that are in Texas, such as the bus driver, aide, dispatcher,
school employees, the plaintiffs, B.L., B.L.’s caretakers, and 11 of 13 medical providers who
treated B.L. The cost of obtaining the Texas witnesses would be significant where the witnesses
would need to travel extensively. See Hansen-Runge, 2020 IL App (1st) 190383, ¶ 29. Therefore,
unlike the circuit court, we find this factor is not neutral and favors dismissal.
¶ 33 5. Possibility of Viewing the Premises
¶ 34 Another private interest factor is the possibility of viewing the premises, if appropriate.
The possibility of having a jury view the scene of an accident is an important consideration when
ruling on a forum non conveniens motion. Moore v. Chicago & North Western Transportation Co.,
99 Ill. 2d 73, 77 (1983). Our supreme court emphasized that this factor is concerned with the
possibility of viewing the site of injury and not the necessity of viewing the site. Dawdy v. Union
Pacific Railroad Co., 207 Ill. 2d 167, 178 (2003). Here, the court found that access to the location
of the occurrence for review was not relevant in a personal injury case.
¶ 35 The defendant argues that, to the extent the mechanism of the left turn that caused B.L.’s
wheelchair to turn over becomes an issue, the street on which the turn occurred is located in Texas,
and it would be inconvenient for a Will County jury to travel hundreds of miles to view it. The
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defendant also argues that the bus is located in Texas and the jury’s ability to see the area where
B.L. was secured to the bus, and the restraints, may be beneficial given the plaintiffs’ allegations
that the defendant failed to properly secure the wheelchair, inspect the manner in which it was
secured, and correct the allegedly dangerous condition. The plaintiffs argue that (1) the defendant
failed to articulate how a site visit would be relevant as no party pled that the condition of the
roadway on which the bus was traveling was a factor in the wheelchair turning over and (2)
viewing the bus was not practical as it continued to be used after the incident and its ongoing usage
changed its condition. The plaintiffs instead suggest that other forms of evidence, such as video
and photos “likely” taken during the investigation, are more probative.
¶ 36 We first disagree with the circuit court’s conclusion that access to the location of the
occurrence for viewing was not relevant in a personal injury case. Instead, the importance of
viewing the premises turns on the facts of the case and the allegations giving rise to the cause of
action. See Hackl v. Advocate Health & Hospitals Corp., 382 Ill. App. 3d 442, 451-52 (2008)
(viewing of the site is rarely or never called for in medical negligence cases); see also Ammerman
v. Raymond Corp., 379 Ill. App. 3d 878, 891 (2008) (the importance of the factor of a jury possibly
viewing the site is diminished where the case primarily concerns a products liability claim because
it is generally not necessary in such cases).
¶ 37 In accidents involving vehicles, jurors may need to view the accident site to observe road
crossings, signs, and sight lines from the perspective of the parties. See Blake v. Colfax Corp.,
2013 IL App (1st) 122987, ¶¶ 22-23. Here, there are not the same concerns with viewing the
specific road where the injury occurred to enhance a jury’s understanding. See id. The defendant
also stated that viewing the actual bus was a possibility based on the allegations in this case.
However, this argument shifts from viewing a premises to viewing a motor vehicle, which is
11
classified as real evidence and should have been couched within its argument for ease of access to
evidence. Smith v. Jewel Food Stores, Inc., 374 Ill. App. 3d 31, 36 (2007) (a wrecked truck was
classified as real evidence and went to the factor concerning ease of access to evidence rather than
possibility of viewing the premises). The plaintiffs also suggest that any viewing can be
accomplished with video and photos “likely” taken from the inspection. This is speculative as there
is no definitive assertion such exists. Based on the foregoing, we find this factor to be neutral.
¶ 38 6. Practical Considerations
¶ 39 The last private interest factor is the practical considerations that make trial easy,
expeditious, and inexpensive. Dawdy, 207 Ill. 2d at 172. The court in this case found that practical
considerations favored neither party. Practical considerations consist of factors previously
analyzed, such as the availability of the compulsory process to secure the attendance of unwilling
witnesses, the cost to obtain attendance of willing witnesses, and the ability to view the premises
(if appropriate). First American Bank, 198 Ill. 2d at 516. As we already found that two of those
factors favor dismissal and one was neutral, the practical considerations also favor dismissal.
Neither the defendant nor the plaintiffs specifically argue any other practical considerations.
¶ 40 C. Public Interest Factors
¶ 41 We next consider the public interest factors: (1) the administrative difficulties caused when
litigation is handled in congested venues instead of being handled at its origin, (2) the unfairness
of imposing jury duty upon residents of a community with no connection to the litigation, and (3)
the interest in having local controversies decided locally. Fennell, 2012 IL 113812, ¶ 16.
¶ 42 1. Administrative Difficulties
¶ 43 As to administrative difficulties, the circuit court found that 103% of civil cases filed in
Denton County were resolved last year compared to 100.6% in Will County, which was a
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miniscule difference that favored denying the dismissal. The defendant argues, as the difference
between the two counties was so small, the factor should have been found to be neutral rather than
favoring denying the dismissal. We agree and find that this factor is neutral.
¶ 44 2. Unfairness of Imposing Jury Duty
¶ 45 The circuit court also addressed the unfairness of imposing a burden of jury duty on the
residents of Will County. It stated that the defendant was incorporated in Illinois and Will County
residents might want to hear about the incident with alleged negligence in transporting special
needs children. Therefore, it appears the court found that this factor favored denying the dismissal.
¶ 46 The defendant argues that, although the case may be interesting, the location of its
headquarters in Will County was not enough to justify the expense and burden of a jury on Will
County residents and its judicial system where the alleged negligence and injuries took place in
Texas. See Skidmore v. Gateway Western Railway Co., 366 Ill. App. 3d 238, 241-42 (2006)
(Illinois had no interest in being burdened by litigation concerning an automobile accident that
occurred in Missouri and involved Missouri residents just because the defendant’s home office
was in Illinois). The plaintiffs argue that the residents of Will County have an interest in ensuring
local school bus companies comply with applicable laws and hire and train safe drivers who do
not endanger children on school buses. See Koss, 2012 IL App (1st) 120379, ¶ 134 (a forum has
an interest in ensuring the quality of services offered by a corporation headquartered in that forum).
Based on the allegations in the complaint, we agree with both parties and find that it would not be
unfair to impose jury duty in either forum. Therefore, this factor is neutral.
¶ 47 3. Interest in Having Local Controversies Decided Locally
¶ 48 Last, the circuit court also considered the factor of interest in having local controversies
decided locally. It stated that the accident took place in Texas, so there was an interest in having
13
the controversy decided there, which favored dismissal. The parties again argue whether the case
is about corporate decision making at headquarters or where the physical injury occurred. A state
has a decided interest in adjudicating cases alleging injuries that occurred within its borders. Wilder
Chiropractic, Inc. v. State Farm Fire & Casualty Co., 2014 IL App (2d) 130781, ¶ 66. The majority
of the plaintiffs’ allegations in this case centered around actions taken in Texas, where B.L. was
injured. Supra ¶ 5. Thus, we agree with the circuit court that this factor favors dismissal.
¶ 49 D. Balancing the Factors
¶ 50 “Forum non conveniens is a flexible doctrine requiring evaluation of the total
circumstances rather than consideration of any single factor.” Gridley, 217 Ill. 2d at 169. We
consider all factors as a whole, without emphasizing one single factor, and do not weigh the private
interest factors against the public interest factors. Fennell, 2012 IL 113812, ¶ 17. We consider the
unique facts of each case. Langenhorst, 219 Ill. 2d at 443. The proper determination is whether the
balance of factors strongly favors dismissal. Gridley, 217 Ill. 2d at 170.
¶ 51 Based on the foregoing analysis as to each individual factor, we find that the circuit court
abused its discretion when it denied the defendant’s motion to dismiss. Aside from the plaintiffs’
choice of forum, each factor either favored dismissal or was neutral. Accordingly, the balance of
factors strongly favored dismissal. We reverse the circuit court’s judgment and remand with
directions for the court to dismiss the action. See Ill. S. Ct. R. 187(c)(2) (eff. Jan. 1, 2018).
¶ 52 III. CONCLUSION
¶ 53 For these reasons, the judgment of the circuit court of Will County is reversed, and the
cause is remanded to the circuit court with directions to dismiss the action in accordance with
Illinois Supreme Court Rule 187(c)(2) (Jan. 1, 2018).
¶ 54 Reversed and remanded with directions.
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