Seilheimer v. Olsen

Illinois Appellate Court
Civil Court
Forum Non Conveniens
Citation
Case Number: 
2025 IL App (1st) 240418
Decision Date: 
Tuesday, December 30, 2025
District: 
1st Dist.
Division/County: 
2d Div./Cook Co.
Holding: 
Reversed.
Justice: 
ELLIS

In a personal injury lawsuit arising out of an automobile collision, plaintiff appealed from a trial court order granting defendant’s motion for forum non conveniences in which the trial court granted defendant’s request to transfer the case from Cook County to Lake County. The appellate court reversed, finding that defendant, who lived in Cook County, did not carry his burden of demonstrating that Cook County was inconvenient and did not demonstrate that this was the “rare, exceptional case” where the balance of factors strongly favored transfer. (VAN TINE and D.B. WALKER, concurring)