Stefanisin v. Prairie State Energy Campus Management, Inc.

Summary

The Illinois Appellate Court, Fifth District, affirmed the St. Clair County circuit court's denial of defendants' motion to transfer venue to Washington County. The court held that the defendants' pump house and its maintenance constituted an "other office" in St. Clair County under Illinois statutory venue law. The court also affirmed the denial of transfer under forum non conveniens, concluding that the relevant public and private interest factors did not strongly favor Washington County.

Holdings

1. The pump house and its maintenance constituted an "other office" in St. Clair County because it was a fixed place of business at which defendants conducted corporate affairs in furtherance of an integral corporate activity. Venue was therefore proper in St. Clair County.
2. The circuit court did not abuse its discretion by denying defendants' forum non conveniens motion because the private and public interest factors did not strongly favor Washington County over St. Clair County.

Questions Presented

1. Whether the St. Clair County pump house constituted an "other office" or otherwise established statutory venue in St. Clair County under sections 2-101 and 2-102 of the Illinois Code of Civil Procedure.
2. Whether the circuit court abused its discretion by denying defendants' request for dismissal or transfer under the doctrine of forum non conveniens.

Disposition

affirmed