"Supreme Court slams forum shopping," said one headline about yesterday's Gridley decision. But the case really wasn't all that dramatic. The term "forum shopping" doesn't even appear in the opinion.
Gridley began when a plaintiff from Louisiana brought a putative nationwide class action against State Farm in an Illinois state court. Though itself a resident of Illinois, State Farm filed a motion to dismiss based on forum non conveniens. Its motion was denied. In Gridley, the Illinois Supreme Court ruled that the denial was in error: because most of the events occurred in Louisiana, Louisiana was a more convenient forum for the action. Even if State Farm's principal place of business was in Illinois, that was only "one factor to be considered" in the forum non conveniens analysis.
In ruling against the plaintiff, the Supreme Court said it was unimportant whether the class, if certified, might include Illinois residents. Prior to a ruling on class certification, the residence of unnamed class members is irrelevant to the forum non conveniens issue. While the Gridley decision will come in handy for defendants facing an Illinois class action by an out-of-state plaintiff, such cases are rare. Based on my own experience, it is almost always true that at least one of the named plaintiffs resides in the forum county. That's why I don't think the Gridley decision is as dramatic as some newspapers want you to believe.