This Note seeks to place Nixon in the context of Missouri law in order to analyze the court's holding and its attendant consequences. First, this Note will review Missouri's venue law leading up to Nixon. Next, this Note will examine the court's reasoning, consider its interpretation of the newlyenacted venue provision of section 508.012, and explore the issues and implications arising from the decision. Finally, this Note will conclude that in order to mitigate Nixon's departure from the legislative goals of the Tort Reform Act, future courts will limit the decision's reach by failing to apply its reasoning beyond the narrow procedural issue presented in Nixon.

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