JUSTICE WELCH delivered the opinion of the court:

On April 18, 2000, Larry Reichert filed, in the circuit court of Pope County, a petitionfor writ of certiorari seeking the review of a decision of the Court of Claims of the State ofIllinois (Court of Claims) in Reichert's personal-injury action against the Board of Trusteesof the University of Illinois (University). Named as the respondent to the petition is theCourt of Claims. The petition seeks the review of a decision of the Court of Claims whichheld that, because Reichert's personal injuries did not arise out of the University's operationof a "vehicle," Reichert's damages were limited to the statutory maximum of $100,000.

On May 25, 2000, the Court of Claims filed a motion to transfer venue to SangamonCounty, arguing that Pope County was an improper venue and that the only proper venuewas Sangamon County. Reichert opposed the motion, and on January 2, 2001, the motionto transfer venue was denied by the circuit court.

On February 23, 2001, the University filed a petition to intervene in the certiorariaction. Apparently, no party objected. This petition was granted on March 6, 2001.

Also on February 23, 2001, the University filed a motion to transfer venue from PopeCounty to Sangamon County or, in the alternative, to Cook County. The University's motionraises substantially the same points as did the Court of Claims' motion to transfer venue. The record contains no objection or response by Reichert. On March 7, 2001, the circuitcourt of Pope County denied this motion to transfer venue.

The University's petition for leave to appeal to this court was granted on May 7, 2001,pursuant to Supreme Court Rule 306 (166 Ill. 2d R. 306). We note that no party haschallenged the University's standing, as an intervenor, to raise the issue of proper venue.

The Court of Claims did not file a petition for leave to appeal to this court. Accordingly, although properly a party to this appeal, its status before this court is that ofan appellee. Its motion to be realigned as an appellant was denied by an order dated May29, 2001. Nevertheless, the Court of Claims has filed a brief attacking the judgment below. As an appellee, it has no standing to do so but may only argue in support of the judgmentbelow. Accordingly, we will sua sponte strike the brief of the Court of Claims filed hereinand will address ourselves only to the arguments of the University attacking the judgmentbelow. The relevant facts are undisputed. Reichert's personal injuries were incurredin Pope County. In the Court of Claims, all the pleadings were filed and all the proceedingstook place in Sangamon County. The principal, and only, offices of the Court of Claims arelocated in Sangamon and Cook Counties.

We begin with a discussion of the appropriate standard of review, which the partiesdispute. The University insists that because in this case the facts are undisputed, the onlyissue before this court is one of law and review should be de novo. Reichert insists that theappropriate standard of review is whether the trial court abused its discretion. We note asplit of authority on this issue. Several cases hold that the determination of proper venue isdiscretionary with the court and that the trial court's decision should be reviewed todetermine whether it abused its discretion. See Johnson v. Compost Products, Inc., 314 Ill.App. 3d 231, 236 (2000); Wheat v. Wilbur, 261 Ill. App. 3d 323, 324 (1994). Indeed, eventhe Illinois Supreme Court has held that the determination of proper venue is discretionary. See Stambaugh v. International Harvester Co., 102 Ill. 2d 250, 263 (1984).

Nevertheless, in Lake County Riverboat L.P. v. Illinois Gaming Board, 313 Ill. App.3d 943, 951 (2000), the court held that the issue of whether a particular venue is properraises a mixed question of law and fact. The court pointed out that being sued in a propervenue is an important statutory privilege and that a defendant has an absolute right to insistupon a proper venue. Lake County Riverboat L.P., 313 Ill. App. 3d at 951. Because in thatcase the facts were undisputed, the court held that the issue of proper venue was one of lawto be reviewed de novo.

We are persuaded by the reasoning of Lake County Riverboat L.P., 313 Ill. App. 3dat 951. The determination of proper venue is not discretionary; it is compulsory. Althougha defendant may waive the issue of proper venue, once a proper motion to transfer based onimproper venue is raised and proved, the trial court has no discretion but to grant it.

We do not lightly disregard the holding of our supreme court in Stambaugh that thedetermination of proper venue is discretionary. We note, however, that the case upon whichStambaugh relied as authority for the proper standard of review, Morrison v. CommunityUnit School District No. 1, 44 Ill. App. 3d 315 (1976), did not involve a motion to transferfor improper venue. Instead, that case involved a motion to transfer venue to a differentcourt for fear that the inhabitants of the county were prejudiced against the movant and thata fair trial could not be received, pursuant to what was then section 4 of "An Act to revisethe law in relation to change of venue" (Ill. Rev. Stat. 1971, ch. 146, par. 4 (now see 735ILCS 5/2-104 (West 2000))). Such a motion does fall within a trial court's sound discretion. However, in our view, a ruling on a motion to transfer for improper venue is notdiscretionary. Either the facts support venue in the county in which the action was filed orthey do not. Once this factual determination is made, the trial court has no discretion as towhether to grant or deny the motion. Therefore, it seems to us that the proper standard ofreview is, as Lake County Riverboat L.P., 313 Ill. App. 3d at 951, held, a mixed question oflaw and fact. We also note that of the two appellate court decisions cited above which holdthat the appropriate standard of review is the abuse-of-discretion standard, one relied on aforum non conveniens case for authority (Wheat, 261 Ill. App. 3d at 324) and the other reliedon Stambaugh as authority (Johnson, 314 Ill. App. 3d at 236).

Accordingly, we adopt and apply herein the standard of review as set forth in LakeCounty Riverboat L.P.. Because in this case, as in that case, the facts are undisputed, wereview the issue de novo.

Section 2-101 of the Code of Civil Procedure (Code) (735 ILCS 5/2-101 (West2000)) is the general venue provision. It provides that every action must be commencedeither in the county of residence of any defendant who is joined in good faith or in thecounty in which the transaction or some part thereof occurred out of which the cause ofaction arose. 735 ILCS 5/2-101 (West 2000). Under this general venue provision, a privatecorporation is deemed to be a resident of any county in which it has an office or is doingbusiness, a partnership is deemed to be a resident of any county in which it has an office, inwhich it is doing business, or in which a partner resides, and a voluntary unincorporatedassociation is deemed to be a resident of any county in which it has an office or in which anyofficer resides. 735 ILCS 5/2-102 (West 2000).

Section 2-103(a) of the Code sets forth the venue provisions for actions against "apublic, municipal, governmental[,] or quasi-municipal corporation." 735 ILCS 5/2-103(a)(West 2000). It provides that actions must be brought against any of these governmentalbodies in the county in which its principal office is located or in the county in which thetransaction or some part thereof occurred out of which the cause of action arose. 735 ILCS5/2-103(a) (West 2000).

Under these statutory venue provisions, proper venue may rest on one, or both, of twogrounds: the defendant's residence or the county in which occurred some part of thetransaction out of which the cause of action arose, referred to herein as transactional venue. The University argues that, under either the general venue provision or the governmental-body venue provision, the residence of the Court of Claims is not Pope County and venueis not proper in Pope County on the basis of the defendant's residence. The Universityargues that the residence of the Court of Claims is Sangamon County, where the Court ofClaims has its principal office, or, alternatively, Cook County, where the Court of Claimshas an office.

Reichert does not dispute that, under the residency prong of the venue provisions,venue is not proper in Pope County. Instead, Reichert focuses on the transactional prongof the venue provisions, arguing that the transaction out of which his cause of action aroseoccurred in Pope County. We will, therefore, address only the issue of transactionalvenue-that is, whether some part of the transaction out of which the cause of action aroseoccurred in Pope County.

Under the transactional-venue provisions, venue is proper in any county in whichoccurred some part of the transaction out of which the cause of action arose. 735 ILCS 5/2-101, 2-103(a) (West 2000). The venue statutes reflect the legislature's view that a defendantshould not be put to the burden of defending an action in a county where the party does notmaintain an office or do business and where no part of the transaction complained ofoccurred. Bucklew v. G.D. Searle & Co., 138 Ill. 2d 282, 289 (1990). Thus, the venuestatutes developed over time to restrict proper venue to places that are convenient either tothe defendant or to the potential witnesses. Bucklew, 138 Ill. 2d at 288-89.

Under transactional-venue principles, two dependent variables must be analyzed todetermine whether a particular venue is proper: (1) the nature of the cause of action and (2)the place where the cause of action springs into existence. Lake County Riverboat L.P., 313Ill. App. 3d at 952. The place where a transaction or some part thereof occurs, causing anaction to spring into existence, is the place where any significant negotiations were carriedon between the parties, where an agreement was signed, where the agreement was or wassupposed to be performed, or where matters occurred that the plaintiff has the burden ofproving as a part of the cause of action. Lake County Riverboat L.P., 313 Ill. App. 3d at952-53. This is generally the place where the parties' direct dealings occurred while in anadversarial position or where events occurred that altered the parties' legal relationship. Lake County Riverboat L.P., 313 Ill. App. 3d at 953. "Transaction" has been defined toinclude every fact that is an integral part of a cause of action. Kenilworth Insurance Co. v.McDougal, 20 Ill. App. 3d 615, 617 (1974).

The University argues on appeal that the cause of action in this case is one for a writof certiorari and that this cause of action arose in Sangamon County, where the proceedingsand decisions of the Court of Claims sought to be reviewed occurred. Reichert, on the otherhand, argues that the petition for writ of certiorari is simply a review procedure and that hisactual cause of action, for personal injuries, arose in Pope County. Both arguments appearto have merit.

The common law writ of certiorari was developed to provide a means whereby apetitioner who was without an avenue of appeal or direct review could obtain limited reviewof an action by a court or other tribunal exercising quasi-judicial functions. Stratton v.Wenona Community Unit District No. 1, 133 Ill. 2d 413, 427 (1990). The purpose of thewrit is to have the entire record of the inferior tribunal brought before the court to determine,from the record alone, whether that body proceeded according to the applicable law. Stratton, 133 Ill. 2d at 427. In a certiorari proceeding, review is strictly limited to aninspection of the record of the inferior tribunal, and the court cannot consider any matter notappearing of that record. People ex rel. Nelson Brothers Storage & Furniture Co. v. Fisher,373 Ill. 228, 229 (1940). If the circuit court, on the return of the writ, finds from the recordthat the inferior tribunal proceeded according to law, the writ is quashed; however, if theproceedings are not in compliance with the law, the judgment and proceedings shown by thereturn will be quashed. Stratton, 133 Ill. 2d at 427. We note that in Stratton, the supremecourt characterized a certiorari action as a review proceeding, not an independent, originalaction. 133 Ill. 2d at 428.

In Rossetti Contracting Co. v. Court of Claims, 109 Ill. 2d 72, 79 (1985), the IllinoisSupreme Court held that a writ of certiorari could be used to review a decision of the Courtof Claims. The court held that, as the final arbiter of the Illinois Constitution, it had theauthority and responsibility to determine whether the Court of Claims had acted tounconstitutionally deprive a party of its right to due process. Rossetti Contracting Co., 109Ill. 2d at 78. The court explicitly did not hold that a writ of certiorari could be used toreview the correctness of a decision of the Court of Claims based on the merits of an appeal,but only that it could be used to review whether the Court of Claims had actedunconstitutionally. Thus, the use of a writ of certiorari to review decisions of the Court ofClaims has been restricted to an examination of whether the Court of Claims deprived alitigant of due process, and it has not been allowed to extend to the merits of the underlyingcase before the Court of Claims. See Reyes v. Court of Claims, 299 Ill. App. 3d 1097, 1106(1998); Klopfer v. Court of Claims, 286 Ill. App. 3d 499, 502-03 (1997); Hyde Park MedicalLaboratory, Inc. v. Court of Claims, 259 Ill. App. 3d 889, 896 (1994).

Based on this case law, the University appropriately argues that, because certiorarireview is limited to the record before the Court of Claims and cannot go to the merits of theunderlying action, all of the facts giving rise to the cause of action (certiorari) arose inSangamon County, where all of the proceedings and decisions of the Court of Claimsoccurred. Furthermore, the University argues, the policy reasons underlying transactionalvenue-convenience to the defendant and/or potential witnesses-do not support venue inPope County because the facts of Reichert's claim against the University, which occurredin Pope County, cannot be reviewed in this certiorari action. Instead, only the questionwhether the Court of Claims deprived Reichert of due process can be reviewed in thiscertiorari action, and all sources of proof relating to that question are located in SangamonCounty. According to the University, all transactions, and all parts thereof, betweenReichert and the Court of Claims took place in Sangamon County.

Reichert responds that the certiorari action is not a separate, independent cause ofaction but is simply a procedure used to review decisions made by the Court of Claims inthe underlying lawsuit. Thus, according to Reichert, the real cause of action in this case isbetween Reichert and the University, and this cause of action arose in Pope County, whereReichert sustained his injuries.

As we have stated, both arguments appear to have merit. Nevertheless, given thepurpose behind the venue statutes and the true nature of the cause of action, we find thearguments of the University to be persuasive. The cause of action before the circuit courtin this case was one for a writ of certiorari claiming that the Court of Claims had, by itsruling limiting his damages to $100,000, deprived Reichert of due process. The petition forwrit of certiorari did not seek the review of any facts or issues in the underlying personal-injury lawsuit but only sought a determination as to whether the Court of Claims' decisionviolated Reichert's due process rights. The cause of action before the circuit court was notReichert's personal-injury action against the University. Exclusive jurisdiction over thatcause of action rests in the Court of Claims.

Reichert's injury in Pope County gave rise to his cause of action against theUniversity in the Court of Claims. The event that gave rise to Reichert's cause of actionagainst the Court of Claims was its ruling limiting his damages to $100,000. This eventoccurred entirely in Sangamon County.

While a certiorari action is a review procedure, it is also a new cause of action filedin the circuit court. The only issue before the circuit court in a certiorari action seeking thereview of a decision of the Court of Claims is whether the Court of Claims acted so as todeprive the petitioner of due process. None of the issues involved in the underlying causeof action are involved in the certiorari action. In a certiorari proceeding, review is strictlylimited to an inspection of the record of the inferior tribunal, and the court cannot considerany matter not appearing of record. People v. Fisher, 373 Ill. 228, 229 (1940). Furthermore,the proceeding is limited to the question of whether the Court of Claims deprived the litigantof due process, and the proceeding may not reach the merits of the underlying action or thedecisions of the Court of Claims made therein. Thus, all of the facts giving rise to thecertiorari action occurred in Sangamon County or Cook County, where all the proceedingsbefore the Court of Claims occur.

Finally, as the University points out, the policy reasons behind the transactional-venue provisions-convenience to the defendant and/or potential witnesses-simply do notsupport venue in Pope County. Pope County is not convenient to the defendant, and nopotential witnesses to the certiorari action are located in Pope County. Proper venue is animportant privilege belonging to the defendant. Blakey v. Commonwealth Edison Co., 52Ill. App. 3d 454, 456 (1977).

" 'The legislature clearly meant to protect a defendant against being sued in acounty arbitrarily selected by a plaintiff, wherein the defendant does not reside, or inwhich no part of the transaction occurred which gave rise to the cause of action. Ifa plaintiff could so select the county to bring his suit, obviously a defendant wouldbe entirely at his mercy, since such an action could be made oppressive andunbearably costly.' " Blakey, 52 Ill. App. 3d at 456 (quoting Heldt v. Watts, 329 Ill.App. 408, 414 (1946)).

And, as our supreme court has pointed out, the venue provisions are to be liberally construedin order to effect rather than defeat a change of venue. Stambaugh v. InternationalHarvester Co., 102 Ill. 2d 250, 261 (1984).

The proper venue for this certiorari action does not lie in Pope County, but inSangamon County, where the principal office of the Court of Claims is located and,according to an affidavit filed with the University's motion to transfer venue, all pleadingsinvolving Reichert were filed and all orders relating to Reichert were issued and distributed. The trial court erred as a matter of law in concluding otherwise.

For the foregoing reasons, the order of the circuit court of Pope County denying theUniversity's motion to transfer venue is reversed, and pursuant to the power granted us bySupreme Court Rule 366(a)(5) (155 Ill. 2d R. 366(a)(5)), we hereby transfer the venue ofthis certiorari proceeding to the circuit court of Sangamon County.

Reversed; order entered.

KUEHN and RARICK, JJ., concur.