In Ex parte AIG Baker Orange Beach Wharf, [Ms. 1071345] (Ala. Jan. 9, 2009), the Alabama Supreme Court held than an order transferring a case based on forum non conveniens is only proper where venue is proper in the original county.  If venue is improper in the original county, then a transfer based on forum non conveniens is inappropriate, and the case would have to be sent back to the original county, even though venue is not proper there.

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