Amanda Toles, on Behalf of Herself and Her Minor Child, Z.T., et al. v. Mead Johnson & Company, LLC, et al.

Summary

The Illinois Appellate Court, Fifth District, reviews interlocutory appeals concerning personal jurisdiction, venue, and forum non conveniens in consolidated necrotizing enterocolitis lawsuits involving infant formula products. The court analyzes Mead Johnson’s general and specific contacts with Illinois, including its former headquarters, ongoing Illinois operations, product marketing, and distribution activities. The opinion also addresses the defendants’ motions to transfer venue and dismiss or transfer under forum non conveniens.

Holdings

1. Illinois courts had general personal jurisdiction over Mead Johnson because its principal place of business was in Illinois during a substantial portion of the relevant period and, even after its claimed relocation, its continuing Illinois operations were substantial and continuous enough to render it essentially at home in Illinois.
2. Illinois courts had specific personal jurisdiction over Mead Johnson because Mead Johnson purposefully directed its activities at Illinois through continuous marketing, sales, hospital contracts, and WIC-program participation, and the plaintiffs' products-liability claims arose out of or related to those contacts; exercising jurisdiction was also reasonable.
3. The defendants failed to establish that venue in St. Clair County was improper. Mead Johnson did not provide specific facts proving the quantity or volume of its business in the county, and venue established for Mead Johnson also applied to Abbott in cases where Mead Johnson was joined as a defendant.
4. The circuit court did not abuse its discretion by denying the defendants' motions to transfer or dismiss under forum non conveniens because the defendants failed to show that the relevant private and public interest factors strongly favored the proposed alternative forums.

Questions Presented

1. Whether Illinois courts had general and specific personal jurisdiction over Mead Johnson with respect to the nonresident plaintiffs' claims.
2. Whether the defendants established that venue in St. Clair County was improper under Illinois's statutory venue provisions.
3. Whether the defendants established that the private and public interest factors strongly favored transfer or dismissal under the doctrine of forum non conveniens.

Disposition

affirmed