On August 15, 2023, the Missouri Supreme Court in State ex rel. Monsanto Co. v. Mullen, No. SC99942 (Mo. Aug. 15, 2023) (en banc), clarified competing interpretations of Mo. Rev. Stat. 508.010.5(1) (2016) with regard to the proper venue for defendant corporations sued by plaintiffs alleging first injury outside the state of Missouri. In the opinion, the Missouri Supreme Court held that venue is determined based on the location of the defendant corporation’s registered agent at the time the suit is filed, rather than the registered agent’s location on the date of a plaintiff’s first alleged injury, resolving an ambiguity contained in the statute.

In a fact-intensive decision issued on October 22, 2020, the Illinois Supreme Court determined in Sergiu Tabirta v. James J. Cummings, et al. that the mere presence of an employee’s home office in Cook County was insufficient, by itself, to establish proper venue over his employer in the jurisdiction. Merely having an employee with a home office in the venue was insufficient under the circumstances to constitute “doing business” or maintaining an “other office” there to satisfy the requirements of Illinois’ venue statute.