Background
Jeremy Rowe, an Ohio resident, alleged that he suffered serious hand injuries while operating a press brake at his employer CenMac Metal Works’ facility in Marion County, Ohio. He alleged that CenMac and several Ohio-based managers intentionally removed, bypassed, or failed to provide required point-of-operation safety guarding. CenMac had purchased the machine from MC Machinery Systems, an Illinois-based company; Murata Machinery Ltd., a Japanese company, was alleged to have manufactured it.
Rowe sued in Cook County. CenMac and its employee defendants moved to dismiss for lack of personal jurisdiction. MC and Murata separately sought dismissal under forum non conveniens so the claims could proceed in Marion County, Ohio. The circuit court granted both sets of motions.
The Court’s Holding
The appellate court affirmed the dismissal of CenMac and the individual Ohio defendants. Even assuming the purchase of the press brake from an Illinois company could establish purposeful availment, Rowe’s intentional-tort claims did not arise from or relate to that purchase. His theory was instead based on alleged post-purchase alterations or safety failures at the Ohio facility, an intervening alleged act with no sufficient connection to the defendants’ Illinois contact.
The court dismissed Rowe’s challenge to the forum non conveniens ruling involving MC and Murata for lack of appellate jurisdiction. A Rule 187 forum non conveniens dismissal is interlocutory and required a petition for leave to appeal under Illinois Supreme Court Rule 306 within 30 days. Rowe filed an ordinary notice of appeal instead; Rule 304(a) language could not make that ruling final and appealable.
Key Takeaways
- A defendant’s Illinois purchase of equipment does not by itself support specific jurisdiction over claims based on later alleged conduct in another state.
- The “arises from or relates to” requirement imposes a real nexus requirement, even where purposeful availment is assumed.
- An Illinois forum non conveniens ruling under Rule 187 must be challenged through a timely Rule 306 petition for leave to appeal.
Why It Matters
The decision underscores that specific jurisdiction turns on the connection between the forum contact and the asserted claim, not merely on a defendant’s prior commercial transaction with an Illinois business. It also highlights a procedural trap: Rule 304(a) language does not convert an interlocutory forum non conveniens order into an appealable final judgment.
This Rule 23 order is nonprecedential except as permitted by Illinois Supreme Court Rule 23(e)(1).