Wilton v. Illini Manors, Inc. 364 Ill. App. 3d 704 (Ill. App. Ct. 2006)

Nursing home moved to dismiss or, in the alternative, to transfer the case from Madison County to Jersey County based on forum non conveniens. The nursing home was located in Jersey County, but the owner also owned a facility in Madison County. Defendants claimed numerous witnesses would be inconvenienced unless the case was transferred and that Plaintiff was in Jersey County. The court affirmed the trial court’s denial of the motion because Defendant could not show “no connection” to Madison County, some witnesses were there and others were disbursed throughout the State. Absent a strong showing of actual inconvenience, the trial court’s decision to deny a motion to transfer for forum non conveniens should not be disturbed.