forum non conveniens doctrine in Minnesota

16 Minnesota opinions name it 2 courts 1954–2019 0 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

Case	Followed	Cited
Hague v. Allstate Insurance Co.green minn · 1979 · cited in 3 Minnesota opinions naming this issue, 1981–1987 2 sentences 1983Under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by non-resident citizens or non-citizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981). 1981In Hague v. Allstate Insurance Co., 289 N.W.2d 43 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 (1981), we pointed out that, under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by nonresident citizens or noncitizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” 2 Id. at 45.	2	3
Bergquist v. Medtronic, Inc.green minn · 1986 · cited in 2 Minnesota opinions naming this issue, 1999–2009 2 sentences 2009See Piper, 454 U.S. at 255 n. 22, 102 S.Ct. 252 ; Bergquist, 379 N.W.2d at 512 (adopting the Piper rule in Minnesota forum non conveniens analysis); see also Hague v. Allstate Ins. 1999Bergquist v. Medtronic, Inc., 379 N.W.2d 508, 511-12 (Minn.1986); Florance, 360 N.W.2d at 630-31 .	2	2
Piper Aircraft Co. v. Reynogreen scotus · 1982 · cited in 3 Minnesota opinions naming this issue, 1986–2009 2 sentences 2009See Piper, 454 U.S. at 255 n. 22, 102 S.Ct. 252 ; Bergquist, 379 N.W.2d at 512 (adopting the Piper rule in Minnesota forum non conveniens analysis); see also Hague v. Allstate Ins. 1996Differences in the substantive law of two jurisdictions will enter into a forum non conveniens analysis “only if there is absolutely no effective remedy in the alternative forum.” Id.	1	3
Matter of Florancegreen minn · 1985 · cited in 2 Minnesota opinions naming this issue, 1987–1999 2 sentences 1999Bergquist v. Medtronic, Inc., 379 N.W.2d 508, 511-12 (Minn.1986); Florance, 360 N.W.2d at 630-31 . 1987Matter of Florance, 360 N.W.2d 626, 630 (Minn.1985) (citing Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1978), aff'd, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981)).	1	2
Johnson v. Chicago, Burlington & Quincy Railroadgreen minn · 1954 · cited in 2 Minnesota opinions naming this issue, 1956–1985 2 sentences 1985The forum non conveniens rule is “an equitable rule based on the proposition that 43 a court in its discretion may decline to exercise jurisdiction over a transitory cause of action when it appears that the action may more equitably be tried in some other available and competent court.” Johnson v. Chicago, Burlington & Quincy Railroad Co., 243 Minn. 58, 62 , 66 N.W.2d 763, 767 (1954) (footnote omitted). 1985The forum non conveniens rule is “an equitable rule based on the proposition that 43 a court in its discretion may decline to exercise jurisdiction over a transitory cause of action when it appears that the action may more equitably be tried in some other available and competent court.” Johnson v. Chicago, Burlington & Quincy Railroad Co., 243 Minn. 58, 62 , 66 N.W.2d 763, 767 (1954) (footnote omitted).	1	2
Anderson v. Frontier Communicationsgreen minn · 2012 · cited in 1 Minnesota opinions naming this issue, 2017–2017 1 sentence 2017See Anderson v. Frontier Commc’ns, 819 N.W.2d 143, 148 (Minn. 2012); Reider v. Anoka-Hennepin Sch.	1	1
Lonergan v. Crucible Steel Co. of Americagreen ill · 1967 · cited in 1 Minnesota opinions naming this issue, 1987–1987 2 sentences 1987See also Lonergan v. Crucible Steel Co. of America, 37 Ill.2d 599 , 229 N.E.2d 536 (1967) (acceptance or denial of jurisdiction should be decided under doctrine of forum non conveniens, and internal affairs of corporation is only one of the factors to be considered). 1987See also Lonergan v. Crucible Steel Co. of America, 37 Ill.2d 599 , 229 N.E.2d 536 (1967) (acceptance or denial of jurisdiction should be decided under doctrine of forum non conveniens, and internal affairs of corporation is only one of the factors to be considered).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (18)

Case	Cited	Years
Allstate Insurance v. Hague green scotus · 1981 2 sentences 1983Under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by non-resident citizens or non-citizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981). 1983Under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by non-resident citizens or non-citizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981).	3	1981–1987
Gulf Oil Corp. v. Gilbert red scotus · 1947 2 sentences 1956R. (2d) 1015, 1021, we said: “* * * Judicial discretion is the sound choosing by the court, subject to the guidance of the law, between doing or not doing a thing, the doing of which cannot be demanded as an absolute right of the party who asks that it be done.” 3 Abuse means improper use or application. 4 In order for the trial court to properly exercise its discretion in applying the doctrine of forum non conveniens, there are a number of factors it must take into consideration. 5 Probably as good a statement of the principal factors involved as any is that of the United States Supreme Court 1956R. (2d) 1015, 1021, we said: “* * * Judicial discretion is the sound choosing by the court, subject to the guidance of the law, between doing or not doing a thing, the doing of which cannot be demanded as an absolute right of the party who asks that it be done.” 3 Abuse means improper use or application. 4 In order for the trial court to properly exercise its discretion in applying the doctrine of forum non conveniens, there are a number of factors it must take into consideration. 5 Probably as good a statement of the principal factors involved as any is that of the United States Supreme Court	3	1956–1983
Arthur H. Aftanase v. Economy Baler Company, a Corporation green ca8 · 1965 2 sentences 1991Since adopting the Eighth Circuit’s five-factor analysis developed in Aftanase v. Economy Baler Co., 343 F.2d 187 (8th Cir.1965), Minnesota courts have consistently treated these factors as lesser but still relevant considerations in determining jurisdiction. 1991Since adopting the Eighth Circuit's five-factor analysis developed in Aftanase v. Economy Baler Co., 343 F.2d 187 (8th Cir.1965), Minnesota courts have consistently treated these factors as lesser but still relevant considerations in determining jurisdiction.	2	1991–1991
Stewart-Warner Corp. v. Western Electric Co. green scotus · 1981 2 sentences 1987Matter of Florance, 360 N.W.2d 626, 630 (Minn.1985) (citing Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1978), aff'd, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981)). 1983Under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by non-resident citizens or non-citizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981).	2	1983–1987
Williams v. Indiana green scotus · 1981 2 sentences 1987Matter of Florance, 360 N.W.2d 626, 630 (Minn.1985) (citing Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1978), aff'd, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981)). 1983Under the doctrine of forum non conveniens, a court “may decline jurisdiction over transitory causes of action brought by non-resident citizens or non-citizens of this state when it fairly appears that it would be more equitable to have the case tried in another available court of competent jurisdiction.” Hague v. Allstate Insurance Co., 289 N.W.2d 43, 45 (Minn.1979), aff’d, 449 U.S. 302 , 101 S.Ct. 633 , 66 L.Ed.2d 521 , reh’g denied, 450 U.S. 971 , 101 S.Ct. 1494 , 67 L.Ed.2d 623 (1981).	2	1983–1987
Ansello v. Wisconsin Central, Ltd. neutral minn · 2017 1 sentence 2019Ansello v. Wis. Cent., Ltd. , 900 N.W.2d 167 , 173 (Minn. 2017) (citing 14D Charles Alan Wright et al., Federal Practice and Procedure § 3828 (4th ed. 2013) (explaining that forum non conveniens generally applies where the other forum is a foreign country, and in the rare circumstances in which the choice is between a federal and a state forum, only citing examples in which the two fora are in different states)).	1	2019–2019
Paulownia Plantations de Panama Corp. v. Rajamannan green minn · 2009 2 sentences 2016“The first step in a forum non conveniens analysis is for the district court to establish the existence of an available and adequate alternative forum.” Id. 2016Such a forum is available if “the foreign court has jurisdiction over the case and the parties.” Id. at 134 .	1	2016–2016
Hill v. Upper Mississippi Towing Corporation green mnd · 1956 1 sentence 1958Minn.) 141 F. Supp. 692 .	1	1958–1958
Chapman v. Dorsey green minn · 1950 1 sentence 1956"Discretion" is defined in Webster's New International Dictionary (1930) as "Freedom to decide or to act according to one's own judgment." In Chapman v. Dorsey, 230 Minn. 279, 285 , 41 N.W. (2d) 438, 442 , 16 A.L.R. (2d) 1015, 1021, we said: "* * * Judicial discretion is the sound choosing by the court, subject to the guidance of the law, between doing or not doing a thing, the doing of which cannot be demanded as an absolute right of the party who asks that it be done." [3] Abuse means improper use or application. [4] In order for the trial court to properly exercise its discretion in applyin	1	1956–1956
Boright v. Chicago, Rock Island & Pacific Railway Co. neutral minn · 1930 2 sentences 1956Co. 180 Minn. 52 , 230 N. W. 457 , no longer exist and that the Boright case and others of like import in which the forum non conveniens rule had heretofore been rejected were expressly overruled. 1956Co. 180 Minn. 52 , 230 N. W. 457 , no longer exist and that the Boright case and others of like import in which the forum non conveniens rule had heretofore been rejected were expressly overruled.	1	1956–1956
Norwood v. Kirkpatrick green scotus · 1955 2 sentences 1956There is a local interest in having localized controversies decided at home.” While it has now been determined that 62 Stat. 937 , 28 USCA, § 1404(a), is not a codification of the forum non conveniens rule (Norwood v. Kirkpatrick, 349 U. S. 29 , 75 S. Ct. 544 , 99 L. ed. 789), in that under the Federal statute the cause of action is transferred from one court to another instead of being dismissed as under the forum non conveniens rule, substantially the same factors are involved in an exercise of the court’s discretion in applying one rule or the other. 1956There is a local interest in having localized controversies decided at home.” While it has now been determined that 62 Stat. 937 , 28 USCA, § 1404(a), is not a codification of the forum non conveniens rule (Norwood v. Kirkpatrick, 349 U. S. 29 , 75 S. Ct. 544 , 99 L. ed. 789), in that under the Federal statute the cause of action is transferred from one court to another instead of being dismissed as under the forum non conveniens rule, substantially the same factors are involved in an exercise of the court’s discretion in applying one rule or the other.	1	1956–1956
Chapman v. Dorsey green minn · 1950 1 sentence 1956"Discretion" is defined in Webster's New International Dictionary (1930) as "Freedom to decide or to act according to one's own judgment." In Chapman v. Dorsey, 230 Minn. 279, 285 , 41 N.W. (2d) 438, 442 , 16 A.L.R. (2d) 1015, 1021, we said: "* * * Judicial discretion is the sound choosing by the court, subject to the guidance of the law, between doing or not doing a thing, the doing of which cannot be demanded as an absolute right of the party who asks that it be done." [3] Abuse means improper use or application. [4] In order for the trial court to properly exercise its discretion in applyin	1	1956–1956
Universal Adjustment Corp. v. Midland Bank, Ltd., of London green mass · 1933 2 sentences 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L. 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L.	1	1954–1954
Hagen v. Viney green fla · 1936 2 sentences 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L. 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L.	1	1954–1954
Becher v. Contoure Laboratories, Inc. green scotus · 1929 1 sentence 1954In affirming the action of the New York court dismissing the cause of action, the United States Supreme Court said ( 279 U. S. 387 , 49 S. Ct. 356 , 73 L. ed. 752): “* * * the statute applies to citizens of New York as well as to others and puts them on the same footing.	1	1954–1954
Whitney v. Madden green ill · 1948 1 sentence 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L.	1	1954–1954
Eastern Union Co. of Delaware, Inc. v. Moffat Tunnel Improvement District green delsuperct · 1934 2 sentences 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L. 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L.	1	1954–1954
Foss v. Richards green me · 1927 2 sentences 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L. 1954The following states having a constitutional provision similar to that of Minnesota have applied the doctrine of forum non conveniens: Delaware: Eastern Union Co. v. Moffat Tunnel Improvement Dist. 36 Del. 488 , 178 A. 864 ; Florida: Hagen v. Viney, 124 Fla. 747 , 169 So. 391 ; Illinois: Whitney v. Madden, 400 Ill. 185 , 79 N. E. (2d) 593; Maine: Foss v. Richards, 126 Me. 419 , 139 A. 313 ; Massachusetts: Universal Adjustment Corp. v. Midland Bank, 281 Mass. 303 , 184 N. E. 152 , 87 A. L.	1	1954–1954

Statutes the citing opinions construe

MN § Minn. Stat. § 543.19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 259 (1948–2026) PA 113 (1959–2026) TX 110 (1960–2025) CA 109 (1953–2026) NY 105 (1943–2025) FL 88 (1954–2024) AL 74 (1990–2025) DE 68 (1961–2026) NJ 48 (1954–2024) OH 46 (1936–2025) CT 44 (1985–2020) MI 31 (1973–2020) DC 31 (1957–2015) WA 28 (1959–2026) MO 25 (1958–2023) WV 24 (1963–2026) MA 20 (1936–2024) MT 18 (1961–2017) GA 18 (1956–2025) LA 17 (1971–2010) MN 16 (1954–2019) MS 14 (1968–2020) TN 12 (1989–2025) MD 10 (1995–2025) ME 10 (1989–2020) NM 10 (1979–1998) KY 9 (1981–2023) OR 9 (1968–2025) IN 9 (1985–2019) CO 9 (1972–2019) OK 8 (1974–2014) RI 8 (2001–2016) UT 7 (1950–2023) SD 6 (1990–2015) VA 6 (1991–2013) AR 6 (1957–2010) NV 6 (2013–2022) AK 6 (1985–2024) NC 5 (2014–2020) WY 4 (1999–2024) KS 4 (1962–1990) IA 3 (1995–2018) NH 3 (1988–2007) AZ 3 (1978–2024) ND 2 (2009–2009) VI 2 (2023–2023) HI 2 (1948–1998) NE 2 (2007–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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