Camperos v. Estrella

Leonor Sarmiento Camperos (Sarmien-to) appeals a non-final order denying her motion to dismiss a circuit court lawsuit against her on grounds of forum non con-veniens. We reverse and remand the case so that the trial court1 may articulate its findings on each of the “Kinney factors”2 determinative of such motions.

A trial court’s order denying a motion to dismiss on grounds of forum non conveniens is subject to reversal and remand as insufficient where, as here, there is neither (1) “meaningful analysis” in the order, nor (2) a transcript reflecting “an adequate analysis of the Kinney factors…