The Illinois Supreme Court issued a decisive blow on June 4, 2020, to destination plaintiffs seeking to forum-shop in Illinois. Following the U.S. Supreme Court’s lead, the Illinois top court held in Christy Rios et al. v. Bayer Corp. et al., 2020 IL 125020 (June 4, 2020), that Illinois lacks personal jurisdiction over nonresident defendants when there is no “meaningful” link between the defendants’ conduct in Illinois and the nonresident plaintiffs’ claims. Notwithstanding nonresident defendants’ general and purposeful activities in the state or the similarity of claims of resident plaintiffs, “Illinois has no particular interest in resolving claims that did not arise out of or relate to activities that occurred here.” Id. ¶ 31. Accordingly, out-of-state corporations will no longer be forced to litigate mass tort or class action claims in Illinois against nonresident plaintiffs whose injuries arose elsewhere.
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