Farm Bureau Mutual Insurance Company of Arkansas, Inc. v. Barbara Gadbury-Swift

Summary

The court held that a circuit court may not use forum non conveniens to transfer an action to another Arkansas county when the plaintiff selected a statutorily authorized venue. It further held that the inconvenient-forum statute addresses interstate disputes and does not expand forum non conveniens to intrastate venue disputes, and that the insurance venue statute does not apply to an insurer's declaratory-judgment action against an insured. The transfer order was reversed and the matter was remanded for further proceedings.