Illinois Supreme Court’s State Farm Ruling Spotlights Venue Shopping

The Illinois Supreme Court ruled that a lawsuit brought in Illinois by a Louisiana plaintiff did not belong in an Illinois state court.

In Gridley v. State Farm, the high court remanded the issue to the circuit court with directions to grant State Farm’s motion to dismiss, based on the fact that the case did not belong in an Illinois court. State Farm had asked the Fifth District Appellate Court to dismiss the case, which it declined to do. The case was then appealed to the Illinois Supreme Court.

State Farm argued that Louisiana was the proper forum because the lead plaintiff was a Louisiana resident and the allegations of wrongdoing were tied to activities that took place in Louisiana.

Furthermore, the preponderance of witnesses and evidence are located in Louisiana, and the case had no meaningful connection to Madison County, State Farm successfully argued.

Headquarters in state

Aside from State Farm’s corporate headquarters in Bloomington, there was no connection to Illinois, yet the plaintiff brought his case to Madison County, a jurisdiction long characterized as a “judicial hellhole” by critics of trial lawyers.

An amicus brief filed by the American Insurance Association (AIA) and other interests argued that the case underscores the impact of improperly applying the doctrine of forum non conveniens, which allows a court to reject jurisdiction over a case and dismiss it for reasons such as if the convenience of the parties and the interest of justice would be better served if the case were brought in a more proper venue. In this situation, the case belonged in the plaintiff’s home state of Louisiana, they argued.

The National Chamber Litigation Center, the public policy law firm of the U.S. Chamber of Commerce, welcomed the decision.

“The court has sent a clear message that forum shopping and out-of-state lawyers looking for big paydays are no longer welcome in Illinois,” said Robin Conrad, senior vice president. “Cases like Gridley are in large part to blame for Madison County’s reputation as a jackpot jurisdiction.”