That One of Multiple Plaintiffs is a New York Resident Does Not Bar a Forum Non Conveniens Motion

On May 20, 2025, the Court of Appeals issued a decision in Haussmann v. Baumann, 2025 NY Slip Op. 03009, holding that just because one of several plaintiffs was a New York resident did not bar a forum non conveniens motion, explaining:

In general, a decision to grant or deny a motion to dismiss on forum non conveniens grounds is addressed to a court’s discretion, and we will review it only to decide whether discretion has been abused. If the courts below considered the various relevant factors in making such a determination, there has been no abuse of discretion reviewable by this Court, even if we would have weighed those factors differently. Here, Supreme Court considered all relevant factors and made no legal error in doing so. Contrary to plaintiffs’ contention, the court gave due weight to plaintiffs’ choice of forum. That one plaintiff is a New York resident does not mandate a contrary result.

(Internal quotations and citations omitted).

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