Richardson v. Husain

Illinois Appellate Court
Civil Court
Forum Non Conveniens
Citation
Case Number: 
2025 IL App (5th) 240916
Decision Date: 
Wednesday, December 10, 2025
District: 
5th Dist.
Division/County: 
St. Clair Co.
Holding: 
Affirmed.
Justice: 
MOORE

Defendants appealed from a trial court order denying their motion to transfer a medical malpractice complaint under the doctrine of forum non conveniens. The appellate court reviewed the applicable factors and affirmed, finding that it could not conclude that the circuit court’s finding that the defendants failed to meet their burden to establish that the balance of the public and private interest factors strongly favored transfer of venue was not so unreasonable that no court would take the same position. (McHANEY, concurring and SHOLAR, specially concurring)