Cruz v. J & W Enterprises, LLC, 150 So. 3d 190

Crash on I-10 in Mobile County (Oct. 4, 2011) involving tractor-trailers driven by Cruz and Coates; Coates was driving a truck owned by J & W (his employer).
Cruz (plaintiff) is a Texas resident; Coates and J & W are based in Clarke County, Alabama. Cruz did not receive medical treatment in Mobile County after the accident.
Cruz sued Coates and J & W in Clarke Circuit Court alleging negligence/wantonness and negligent/wanton hiring, training, and entrustment by J & W.
Defendants moved to transfer venue to Mobile County under Ala. Code § 6-3-21.1 (forum non conveniens), arguing the "interest of justice" favors Mobile where the accident occurred.
Trial court denied the transfer; defendants petitioned this Court for writ of mandamus to compel transfer. The Supreme Court denied the petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying transfer under the "interest of justice" prong of § 6-3-21.1	Clarke is proper and should be retained because defendants reside / do business there and relevant employment/training records are likely in Clarke; plaintiff's counsel is in Clarke	Mobile has stronger nexus because the accident occurred there and was investigated by Mobile authorities	Denied — court held Mobile's connection was not sufficiently stronger; Clarke's connection was not weak, so trial court did not abuse discretion

Ex parte Southeast Ala. Timber Harvesting, LLC, 94 So.3d 371 (Ala. 2012) (transfer appropriate where transferee county had strong connection and original forum had weak connection)
Ex parte Indiana Mills & Mfg., Inc., 10 So.3d 536 (Ala. 2008) (emphasizing weight of accident location and investigative records in interest-of-justice analysis)
Ex parte McKenzie Oil Co., 13 So.3d 346 (Ala. 2008) (transfer warranted where virtually all material events occurred in transferee county)
Ex parte National Sec. Ins. Co., 727 So.2d 788 (Ala. 1998) (articulating "strong" vs. "little" nexus framework for interest-of-justice prong)
Ex parte Perfection Siding, Inc., 882 So.2d 307 (Ala. 2003) (plaintiff's choice of a proper forum is given great deference)