Plaintiff, an Iranian citizen, filed action for fraud and legal malpractice, as to her immigration law matter, against Defendant attorney, who is a Canadian citizen and licensed to practice law in Illinois. Circuit court properly dismissed case with prejudice, as it lacked personal jurisdiction over Defendant. Agreement between the parties was for services and advice as to immigration, with no indication that the services or advice would be provided in Illinois. Defendant performed no relevant action or event in Illinois within the relevant period. Illinois has no stake in adjudicating the dispute, and Plaintiff has not shown that Illinois is a more appropriate forum than another such as Quebec where Defendant resides. (CUNNINGHAM and CONNORS, concurring.)
Illinois Appellate Court
Civil Court
Personal Jurisdiction