Mountain View Recreation v. Imperial Commercial Cooking Equip. Co.
Annotate this CaseAfter a fire destroyed a recreation center in Nye County, Appellant, which owned and operated the center, filed a complaint in Nye County against numerous defendants. Some defendants filed a motion for change of venue to Clark County. The district court granted the motion based on the convenience of the witnesses and the promotion of the ends of justice, finding that the existing courtroom facilities in Nye County were inadequate for a trial of this size. The district court then concluded that, under the doctrine of forum non conveniens, the trial should be transferred to Clark County. The Supreme Court reversed, holding (1) to the extent the district court relied on the doctrine of forum non conveniens as a basis for its decision, there was insufficient evidence to support such a finding; (2) the district court abused its discretion in failing to analyze and provide specific findings regarding whether existing courtroom facilities in Nye County could be made adequate and whether there were alternative facilities in the county that could be utilized to accommodate the trial; and (3) the district court abused its discretion by failing to consider Clark County's court schedule and docket congestion before ordering a change of venue. Remanded.
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