litigants and public interest factors in Illinois

49 Illinois opinions name it 2 courts 1987–2025 14 in the last five years

The cases below were cited by Illinois 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 (9)

Case	Followed	Cited
Van Dusen v. Barrackgreen scotus · 1964 · cited in 5 Illinois opinions naming this issue, 2019–2025 2 sentences 2025“Every request for transfer based upon forum non conveniens must be decided pursuant to an ‘individualized, case-by-case consideration of convenience and fairness.’ ” Gridley, 217 Ill. 2d at 168 (quoting Van Dusen v. Barrack, 376 U.S. 612, 622 (1964)). ¶ 16 In determining whether to grant or deny a motion to dismiss based on the doctrine of forum non conveniens, the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts. 2025“Every request for transfer based upon forum non conveniens must be decided pursuant to an ‘individualized, case-by-case consideration of convenience and fairness.’ ” Gridley, 217 Ill. 2d at 168 (quoting Van Dusen v. Barrack, 376 U.S. 612, 622 (1964)). 7 ¶ 21 In determining whether to grant or deny a motion to dismiss on the basis of forum non conveniens, the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.	5	5
Gulf Oil Corp. v. Gilbertred scotus · 1947 · cited in 10 Illinois opinions naming this issue, 1987–2020 2 sentences 1994It presupposes the existence of more than one forum with jurisdiction over the parties and the subject matter. [Citations.] Under the doctrine, a court may decline to exercise jurisdiction of a case whenever it appears that there is another forum with jurisdiction of the parties in which trial can be more conveniently had. [Citations.] In deciding whether the doctrine applies, a court must balance private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts. [Citation.] Factors relating to the private interests of th 1994It presupposes the existence of more than one forum with jurisdiction over the parties and the subject matter. [Citations.] Under the doctrine, a court may decline to exercise jurisdiction of a case whenever it appears that there is another forum with jurisdiction of the parties in which trial can be more conveniently had. [Citations.] In deciding whether the doctrine applies, a court must balance private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts. [Citation.] Factors relating to the private interests of th	3	10
Adkins v. Chi. R. Is. & Pac. RR Co.green ill · 1973 · cited in 2 Illinois opinions naming this issue, 2006–2006 2 sentences 2006App. 3d at 70 , 704 N.E.2d at 837 ), and allows the court to decline jurisdiction “whenever it appears that there is another forum that can better ‘serve the convenience of the parties and the ends of justice.’ ” Adkins, 54 Ill. 2d at 514, 301 N.E.2d at 730, quoting Lonergan v. Crucible Steel Co. of America, 37 Ill. 2d 599, 606 , 229 N.E.2d 536, 539 (1967). 2006App. 3d at 70 , 704 N.E.2d at 837 ), and allows the court to decline jurisdiction “whenever it appears that there is another forum that can better ‘serve the convenience of the parties and the ends of justice.’ ” Adkins, 54 Ill. 2d at 514, 301 N.E.2d at 730, quoting Lonergan v. Crucible Steel Co. of America, 37 Ill. 2d 599, 606 , 229 N.E.2d 536, 539 (1967).	2	2
Lonergan v. Crucible Steel Co. of Americagreen ill · 1967 · cited in 2 Illinois opinions naming this issue, 2006–2006 2 sentences 2006App. 3d at 70 , 704 N.E.2d at 837 ), and allows the court to decline jurisdiction “whenever it appears that there is another forum that can better ‘serve the convenience of the parties and the ends of justice.’ ” Adkins, 54 Ill. 2d at 514, 301 N.E.2d at 730, quoting Lonergan v. Crucible Steel Co. of America, 37 Ill. 2d 599, 606 , 229 N.E.2d 536, 539 (1967). 2006App. 3d at 70 , 704 N.E.2d at 837 ), and allows the court to decline jurisdiction “whenever it appears that there is another forum that can better ‘serve the convenience of the parties and the ends of justice.’ ” Adkins, 54 Ill. 2d at 514, 301 N.E.2d at 730, quoting Lonergan v. Crucible Steel Co. of America, 37 Ill. 2d 599, 606 , 229 N.E.2d 536, 539 (1967).	2	2
Washington v. Illinois Power Co.green ill · 1991 · cited in 2 Illinois opinions naming this issue, 2001–2001 2 sentences 2001Griffith, 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co., 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill, 207 Ill. 2001Griffith, 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co., 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill, 207 Ill.	2	2
Dawdy v. Union Pacific RR Co.green ill · 2003 · cited in 15 Illinois opinions naming this issue, 2011–2025 2 sentences 2023“The doctrine allows the court in which the action was filed to decline jurisdiction and direct the lawsuit to an alternative forum that the court -9- No. 1-22-0045 determines can better serve the convenience of the parties and the ends of justice.” Dawdy, 207 Ill. 2d at 171-72 . ¶ 29 In deciding a forum non conveniens motion, a circuit court “must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” (Internal quotation marks omitted.) Kuhn v. Nicol, 2020 IL App (5th) 190225, ¶ 11 . 2023“The doctrine allows the court in which the action was filed to decline jurisdiction and direct the lawsuit to an alternative forum that the court determines can better serve the convenience of the parties and the ends of justice.” Dawdy, 207 Ill. 2d at 171-72. ¶ 30 In deciding a forum non conveniens motion, a circuit court “must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” Kuhn v. Nicol, 2020 IL App (5th) 190225, ¶ 11 .	1	15
First Nat. Bank v. Guerinegreen ill · 2002 · cited in 1 Illinois opinions naming this issue, 2024–2024 1 sentence 2024The private interest factors include: “(1) the convenience of the parties; (2) the relative ease of access to sources of testimonial, documentary, and real evidence; and (3) all other practical problems that make trial of a case easy, expeditious, and inexpensive,” including the “ability to view the premises (if appropriate).” Guerine, 198 Ill. 2d at 516. ¶ 66 Regarding the convenience of the parties, we assume that plaintiff’s choice of its home forum is convenient to plaintiff.	1	1
Satkowiak v. Chesapeake & Ohio Railway Co.green ill · 1985 · cited in 1 Illinois opinions naming this issue, 2013–2013 1 sentence 2013Co., 106 Ill. 2d 224, 228 (1985); Foster, 102 Ill. 2d at 381-82 ; Jones v. Searle Laboratories, 93 Ill. 2d 366, 372-73 (1982). ¶ 15 In Gulf Oil, the Court discussed private interest factors affecting the litigants and public interest factors affecting court administration.	1	1
Jones v. Searle Laboratoriesgreen ill · 1982 · cited in 1 Illinois opinions naming this issue, 2013–2013 1 sentence 2013Co., 106 Ill. 2d 224, 228 (1985); Foster, 102 Ill. 2d at 381-82 ; Jones v. Searle Laboratories, 93 Ill. 2d 366, 372-73 (1982). ¶ 15 In Gulf Oil, the Court discussed private interest factors affecting the litigants and public interest factors affecting court administration.	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (20)

Case	Cited	Years
Gridley v. State Farm Mutual Automobile Insurance green ill · 2005 2 sentences 2025“Every request for transfer based upon forum non conveniens must be decided pursuant to an ‘individualized, case-by-case consideration of convenience and fairness.’ ” Gridley, 217 Ill. 2d at 168 (quoting Van Dusen v. Barrack, 376 U.S. 612, 622 (1964)). ¶ 16 In determining whether to grant or deny a motion to dismiss based on the doctrine of forum non conveniens, the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts. 2025“Every request for transfer based upon forum non conveniens must be decided pursuant to an ‘individualized, case-by-case consideration of convenience and fairness.’ ” Gridley, 217 Ill. 2d at 168 (quoting Van Dusen v. Barrack, 376 U.S. 612, 622 (1964)). 7 ¶ 21 In determining whether to grant or deny a motion to dismiss on the basis of forum non conveniens, the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.	8	2006–2025
Griffith v. Mitsubishi Aircraft International, Inc. green ill · 1990 2 sentences 2001Griffith, 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co., 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill, 207 Ill. 2001Griffith, 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co., 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill, 207 Ill.	5	1990–2001
Langenhorst v. Norfolk Southern Ry. Co. green ill · 2006 2 sentences 2011Langenhorst, 219 Ill. 2d at 442 . 2011Langenhorst, 219 Ill. 2d at 442 .	3	2009–2011
Bland v. Norfolk & Western Railway Co. green ill · 1987 2 sentences 1990Co. (1987), 116 Ill. 2d 217, 223 , 506 N.E.2d 1291, 1294 .) In resolving a forum non conveniens question, the court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts. 116 Ill. 2d at 223-24 , 506 N.E.2d at 1294 . 1990Co. (1987), 116 Ill. 2d 217, 223 , 506 N.E.2d 1291, 1294 .) In resolving a forum non conveniens question, the court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts. 116 Ill. 2d at 223-24 , 506 N.E.2d at 1294 .	3	1989–1990
Pierce v. Cherukuri green illappct · 2022 2 sentences 2023The private interest factors include “(1) convenience of the parties; (2) the relative ease of access to sources of testimonial, documentary, and real evidence; (3) the availability of compulsory process to secure attendance of unwilling witnesses; (4) the cost to obtain attendance of willing witnesses; (5) the possibility of viewing the premises, if appropriate; and (6) all other practical considerations that make a trial easy, expeditious, and inexpensive.” Pierce, 2022 IL App (1st) 210339, ¶ 22 . ¶ 30 The public interest factors include (1) the community’s interest in having localized contr 2023The private interest factors include: “(1) convenience of the parties; (2) the relative ease of access to sources of testimonial, documentary, and real evidence; (3) the availability of compulsory process to secure attendance of unwilling witnesses; (4) the cost to obtain attendance of willing witnesses; (5) the possibility of viewing the premises, if appropriate; and (6) all other practical considerations that make a trial easy, expeditious, and inexpensive.” Pierce, 2022 IL App (1st) 210339, ¶ 22 . ¶ 31 The public interest factors include: (1) the community’s interest in having localized con	2	2023–2023
Kuhn v. Nicol green illappct · 2020 2 sentences 2023“The doctrine allows the court in which the action was filed to decline jurisdiction and direct the lawsuit to an alternative forum that the court -9- No. 1-22-0045 determines can better serve the convenience of the parties and the ends of justice.” Dawdy, 207 Ill. 2d at 171-72 . ¶ 29 In deciding a forum non conveniens motion, a circuit court “must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” (Internal quotation marks omitted.) Kuhn v. Nicol, 2020 IL App (5th) 190225, ¶ 11 . 2023“The doctrine allows the court in which the action was filed to decline jurisdiction and direct the lawsuit to an alternative forum that the court determines can better serve the convenience of the parties and the ends of justice.” Dawdy, 207 Ill. 2d at 171-72. ¶ 30 In deciding a forum non conveniens motion, a circuit court “must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” Kuhn v. Nicol, 2020 IL App (5th) 190225, ¶ 11 .	2	2023–2023
Fennell v. Illinois Central R.R. Co. green ill · 2013 2 sentences 2021Co., 2012 IL 113812 , ¶ 12 and Ruch v. Padgett, 2015 IL App (1st) 142972, ¶ 37 ). ¶ 22 In order to disturb the plaintiff’s choice of forum, the defendant bears the burden to show that the relevant private interest factors affecting the litigants and public interest factors affecting court administration “strongly favor” the defendant’s suggested forum. 2015Fennell, 2012 IL 113812, ¶ 14 . ¶ 41 Illinois courts weigh various interests, grouped into private-interest factors affecting the litigants and public-interest factors affecting court administration.	2	2015–2021
Foster v. CHICAGO & N. WEST TRANS. CO. green ill · 1984 2 sentences 2013Co., 106 Ill. 2d 224, 228 (1985); Foster, 102 Ill. 2d at 381-82 ; Jones v. Searle Laboratories, 93 Ill. 2d 366, 372-73 (1982). ¶ 15 In Gulf Oil, the Court discussed private interest factors affecting the litigants and public interest factors affecting court administration. 1993(Foster v. Chicago & North Western Transportation Co. (1984), 102 Ill. 2d 378, 382 , 466 N.E.2d 198 .) In addressing a forum non conveniens question, courts must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.	2	1993–2013
Ferguson v. Bill Berger Associates, Inc. green illappct · 1998 2 sentences 2006A forum non conveniens argument asks the court to consider private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts (Ferguson, 302 Ill. 2006A forum non conveniens argument asks .the court to consider private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts (Ferguson, 302 Ill.	2	2006–2006
Schoon v. Hill green illappct · 1991 2 sentences 2001Griffith, 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co., 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill, 207 Ill. 2001Griffith , 136 Ill. 2d at 105 , 554 N.E.2d at 211 ; Washington v. Illinois Power Co. , 144 Ill. 2d 395, 399 , 581 N.E.2d 644, 645 (1991); Schoon v. Hill , 207 Ill.	2	2001–2001
Broeker v. Turville green illappct · 1993 2 sentences 2001Broeker, 257 Ill. 2001Broeker, 257 Ill.	2	2001–2001
Vinson v. Allstate green ill · 1991 2 sentences 1998Vinson , 144 Ill. 2d 306 , 579 N.E.2d 857 ; Trent , 234 Ill. 1998Vinson , 144 Ill. 2d 306 , 579 N.E.2d 857 ; Trent , 234 Ill.	2	1998–1998
Trent v. Caterpillar, Inc. green illappct · 1992 2 sentences 1998Vinson , 144 Ill. 2d 306 , 579 N.E.2d 857 ; Trent , 234 Ill. 1998Vinson, 144 Ill. 2d 306 , 579 N.E.2d 857 ; Trent, 234 Ill.	2	1998–1998
Campbell v. Autenrieb green illappct · 2018 1 sentence 2025A circuit court “abuses its discretion only if it acts arbitrarily without the employment of conscientious judgment, exceeds the bounds of reason and disregards recognized principles of law, or if no reasonable person would take the position adopted by the [circuit] court.” Campbell v. Autenrieb, 2018 IL App (5th) 170148, ¶ 26 . ¶ 69 In deciding a motion on the basis of forum non conveniens, “the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” (Internal quotation marks omitted.) Wylie v. Schaef	1	2025–2025
Wylie v. Schaefer green illappct · 2021 1 sentence 2025A circuit court “abuses its discretion only if it acts arbitrarily without the employment of conscientious judgment, exceeds the bounds of reason and disregards recognized principles of law, or if no reasonable person would take the position adopted by the [circuit] court.” Campbell v. Autenrieb, 2018 IL App (5th) 170148, ¶ 26 . ¶ 69 In deciding a motion on the basis of forum non conveniens, “the circuit court must balance private interest factors affecting the litigants and public interest factors affecting the administration of the courts.” (Internal quotation marks omitted.) Wylie v. Schaef	1	2025–2025
Ruch v. Padgett green illappct · 2015 1 sentence 2021Co., 2012 IL 113812 , ¶ 12 and Ruch v. Padgett, 2015 IL App (1st) 142972, ¶ 37 ). ¶ 22 In order to disturb the plaintiff’s choice of forum, the defendant bears the burden to show that the relevant private interest factors affecting the litigants and public interest factors affecting court administration “strongly favor” the defendant’s suggested forum.	1	2021–2021
Boner v. Peabody Coal Co. green ill · 1991 2 sentences 1995(Boner v. Peabody Coal Co. (1991), 142 Ill. 2d 523 , 568 N.E.2d 883 ; Griffith v. Mitsubishi Aircraft International, Inc. (1990), 136 Ill. 2d 101 , 554 N.E.2d 209 ; McClain v. Illinois Central Gulf R.R. 1995(Boner v. Peabody Coal Co. (1991), 142 Ill. 2d 523 , 568 N.E.2d 883 ; Griffith v. Mitsubishi Aircraft International, Inc. (1990), 136 Ill. 2d 101 , 554 N.E.2d 209 ; McClain v. Illinois Central Gulf R.R.	1	1995–1995
Mowen v. Illinois Valley Supply Co. green illappct · 1994 1 sentence 1995(Weaver, 116 Ill. 2d 279 , 507 N.E.2d 838 ; Mowen v. Illinois Valley Supply Co. (1994), 257 Ill.	1	1995–1995
Weaver v. Midwest Towing, Inc. green ill · 1987 2 sentences 1995(Weaver, 116 Ill. 2d 279 , 507 N.E.2d 838 ; Mowen v. Illinois Valley Supply Co. (1994), 257 Ill. 1995(Weaver, 116 Ill. 2d 279 , 507 N.E.2d 838 ; Mowen v. Illinois Valley Supply Co. (1994), 257 Ill.	1	1995–1995
Moore v. Chicago & North Western Transportation Co. green ill · 1983 2 sentences 1995(Moore v. Chicago & North Western Transportation Co. (1983), 99 Ill. 2d 73 , 457 N.E.2d 417 .) The resolution of a forum non conveniens motion requires the court to apply an uneven balancing test to various private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts. 1995(Moore v. Chicago & North Western Transportation Co. (1983), 99 Ill. 2d 73 , 457 N.E.2d 417 .) The resolution of a forum non conveniens motion requires the court to apply an uneven balancing test to various private interest factors affecting the convenience of the litigants and public interest factors affecting the administration of the courts.	1	1995–1995

Statutes the citing opinions construe

IL § 735 ILCS 5/2-101 (6) USC § 45u.s.c.51 (4) USC § 45u.s.c.56 (4) IL § 815 ILCS 505/1 (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.

← Caselaw search · G Cite Topics · Brief Check