Illinois Central Railroad Company v. Samson

Summary

The Supreme Court of Mississippi reviewed an interlocutory appeal concerning Illinois Central Railroad Company's motion to dismiss a Federal Employers' Liability Act action on forum non conveniens grounds. The court held that Mississippi was not an inconvenient forum after balancing the relevant private and public interest factors and affirmed the denial of the motion to dismiss.

Holdings

1. The circuit court correctly denied Illinois Central's motion to dismiss because, after balancing the seven forum non conveniens factors, Mississippi was not an inconvenient forum and Samson's choice of forum was entitled to deference.
2. The circuit court was not required on its own initiative to make findings of fact supporting its denial of the forum non conveniens motion, and Illinois Central could not complain about the absence of findings because it had not requested them.

Questions Presented

1. Whether the Hinds County Circuit Court erred by denying Illinois Central's motion to dismiss under the doctrine of forum non conveniens.
2. Whether the circuit court was required to make findings of fact on the record explaining its denial of the forum non conveniens motion.

Disposition

affirmed