Scharf Banks Marmor Wins Dismissal of Contract Claims For Medical LLC Clients

Stephanie Scharf and George Sax have won dismissal of all contract claims against their medical profession clients, resulting in the Lexis-published opinion Naughton v. Humes, et al., No. 2023 CH 08048, 2024 Ill. Cir. LEXIS 2 (Cook Cnty. Mar. 20, 2024) .  The Naughton opinion enforced a contract’s forum selection clause and, consistent with Illinois policy, rejected the argument that a dispute over the value of the consideration would negate the forum clause.  The court also found that the State of Illinois lacked personal jurisdiction over an out-of-state codefendant medical clinic, underscoring the rule that Illinois “cannot exercise personal jurisdiction over one corporation merely because a related corporation conducts business in Illinois.”  The dispute involved transactions among individuals and their medical services corporations in Colorado and Illinois.