Venue of Trial In a Lawsuit Against Multiple Public Corporations In Different Counties

In Lawless v. Village of Park Forest South, 108 Ill. App. 3d 191, 438 N.E.2d 1299, 63 Ill. Dec. 936 (1982), the plaintiff brought suit against several municipal corporations, headquartered in different counties. Lawless, 108 Ill. App. 3d at 192. These defendants sought to apply section 2-103(a), which would have required the plaintiff to pursue a separate case in each applicable county. Lawless, 108 Ill. App. 3d at 194. The plaintiff argued that the general venue provision, section 2-101 of the Code of Civil Procedure (Ill. Rev. Stat. 1981, ch. 110, par. 2-101), applied. This provision fixes venue in the county of residence of any defendant joined in good faith or in a county where part of the cause of action arose. Lawless, 108 Ill. App. 3d at 194. The court held that when multiple public corporations, with "principal offices" in different counties, are defendants in a single action, sections 2-103(a) and 2-101 must be read together, and the "principal office" of a public corporation is equivalent to its "residence." The court concluded that in such a situation, venue is proper in the county of residence of any public corporation joined in good faith. Lawless, 108 Ill. App. 3d at 196-97.