Missouri Court of Appeals for the Eastern District Addresses the Effect of the 2005 Amended Venue Statute on Permissive Joinder

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In a case of first impression, the Missouri Court of Appeals for the Eastern District has addressed the very narrow issue of what effect the permissive joinder rule has on venue where a plaintiff suffers injuries from separate, successive accidents in different counties within the State of Missouri. The Court concludes the new venue statute eliminates any ambiguity which might have existed pre-tort reform in terms of the interplay between the permissive joinder rules and the venue rules. According to the Court, the new statute unambiguously confers venue in the county of the first injury for separate, yet successive accidents occurring in different counties.

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