Construction clients very often perform work in places far from either the corporate office, or far from the construction client's local office. Our clients even perform work - dare we admit - far from their attorney's office. At the same time, many construction clients want both consistency in their contracts and convenience to their local court system. For this reason, attorneys often include a "Choice of Venue" clause in the construction contract that directs any litigation or alternative dispute resolution procedures to take place in a designated venue. Usually, the chosen venue is the county in which the attorney practices or the county where the construction client has its corporate office.

Now imagine a situation in which the construction client performed work in a county or State other than the one designated as the agreed-upon Choice of Venue. In Florida, despite the negotiated and agreed contractual language, there are circumstances in which courts have directed parties to resolve their dispute in an alternate venue.