This is an appeal from the circuit court's denial of the motion to transfer venue filedby the Illinois Health Facilities Planning Board (defendant). The issue for review is whetherthe circuit court erred in denying defendant's motion to transfer. We affirm.

Defendant is a regulatory body of the State of Illinois pursuant to the Illinois HealthFacilities Planning Act (20 ILCS 3960/1 et seq. (West 2000)), and it is charged withregulating the construction, modification, and establishment of health care facilities in thestate. On May 21, 1999, defendant approved the application of Marion Hospital Corp. (thehospital) to construct a 92-bed hospital in Williamson County to replace the hospital'sexisting facility, also located in Williamson County. On June 9, 1999, defendant issued thehospital a permit for the construction of the replacement hospital. The permit required thehospital "to reach a fair resolution with respect to current local union issues and *** useunion labor to construct the replacement hospital."

On June 21, 2000, before the hospital began construction, the Southern and CentralIllinois Laborers' District Council (plaintiff) provided defendant with a written noticeclaiming that the hospital had failed to comply with the conditions of its construction permitrelating to local union issues. Plaintiff informed defendant that an April 29, 1999, orderissued by an administrative law judge of the National Labor Relations Board found that thehospital had engaged in unfair labor practices. Further, plaintiff claimed that the hospitalcontinued the same unfair labor practices while the administrative law judge's ruling was onappeal. In response to plaintiff's claims, defendant put the matter on the agenda for itsAugust 24, 2000, scheduled meeting. At this meeting, held in Cook County, defendantheard testimony from two representatives of the hospital on the union issues but refused torecognize plaintiff's representative, who was seated in the audience.

On September 25, 2000, plaintiff sent defendant a letter communicating itsdissatisfaction with the manner in which the meeting was conducted, citing specificinstances it considered procedurally and substantively deficient. In the letter, plaintiff urged defendant to follow its statutory mandate and pursue the allegations that the hospital hadbreached conditions of its construction permit. On November 14, 2000, plaintiff filed acomplaint for mandamus, alleging that defendant did not comply with the procedures andsubstance of the Illinois Administrative Procedure Act (5 ILCS 100/1-1 et seq. (West 2000))when conducting the August 24, 2000, meeting. In its complaint, plaintiff alleged thatdefendant failed to recognize that the allegations of noncompliance against the hospitalrequired a contested case under the Illinois Administrative Procedure Act. Plaintiff'scomplaint asserted that the commencement of construction by the hospital violated theconditions of the hospital's permit and that defendant failed to ensure that the hospital wasin compliance with the terms of the permit. Plaintiff's mandamus action seeks to requiredefendant to hold a hearing under the Illinois Administrative Procedure Act to determine thecontested case as to whether the hospital was in compliance with its permit prior to the startof construction.

On December 6, 2000, the individual members of defendant (who had also beennamed as defendants in plaintiff's complaint) filed a motion to transfer venue to SangamonCounty pursuant to section 2-104 of the Code of Civil Procedure (the Code) (735 ILCS 5/2-104 (West 2000)). On December 26, 2000, defendant itself filed a motion to transfer venueto Sangamon County. The venue hearing was held on January 30, 2001, at which timeplaintiff voluntarily dismissed its claims against the individual members of defendant, andon January 31, 2001, the court denied defendant's motion to transfer venue. Defendant madea timely appeal.

We first address defendant's contention that a de novo standard should be employedin this review of the circuit court's denial of its motion to transfer venue. Defendant reliesheavily on Lake County Riverboat L.P. v. Illinois Gaming Board, 313 Ill. App. 3d 943, 730N.E.2d 524 (2000), and Reichert v. Court of Claims, 327 Ill. App. 3d 390, 763 N.E.2d 402(2002), in support of a de novo review of the instant matter. We recognize the differentstandard of review established by the Second District's decision in Lake County RiverboatL.P. but also call attention to the more recent Second District decision of Johnson v.Compost Products, Inc., 314 Ill. App. 3d 231, 731 N.E.2d 948 (2000), where the same courtrejected the de novo standard in reviewing the denial of a motion to transfer venue. Likewise, we are familiar with this court's decision in Reichert, which followed Lake CountyRiverboat L.P.'s application of a de novo review. However, we decline to adopt a de novostandard of review and instead follow the abuse-of-discretion standard of review previouslyenunciated by our supreme court in Stambaugh v. International Harvester Co., 102 Ill. 2d250, 464 N.E.2d 1011 (1984), and adhered to in the Johnson decision.

A trial court has broad discretion when determining where venue is proper, and itsdecision will not be overturned absent an abuse of discretion. Long v. Gray, 306 Ill. App.3d 445, 449, 714 N.E.2d 1041, 1044 (1999) (citing Stambaugh, 102 Ill. 2d at 263, 464N.E.2d at 1016-17 (1984)). "The role of this court is not to substitute its judgment for thatof the trial court, or even to determine whether the trial court exercised its discretion wisely,but rather our role is to determine whether the trial court abused its discretion." Niepotterv. Central Illinois Public Service Co., 303 Ill. App. 3d 632, 636, 707 N.E.2d 1278, 1281(1999). A circuit court abuses its discretion when it "acts arbitrarily, fails to employconscientious judgment[,] and ignores recognized principles of law." Hernandez v. KarlinFoods Corp., 322 Ill. App. 3d 805, 807-08, 751 N.E.2d 27, 29 (2001) (citing Elling v. StateFarm Mutual Automobile Insurance Co., 291 Ill. App. 3d 311, 317, 683 N.E.2d 929, 935(1997)).

The sole issue in the instant appeal is whether the circuit court erred in denyingdefendant's motion to transfer venue from Williamson County. Under section 2-101 of theCode (735 ILCS 5/2-101 (West 2000)), a suit must be brought (1) in the county of residenceof any defendant or (2) in the county in which the transaction or some part thereof occurredout of which the cause of action arose. Section 2-103(a) of the Code (735 ILCS 5/2-103(a)(West 2000)) sets forth provisions for actions against a public, municipal, governmental, orquasi-municipal corporation. Section 2-103(a) provides that actions must be brought againsta governmental body in the county in which its principal office is located or in the countyin which the transaction or some part thereof occurred out of which the cause of actionarose. 735 ILCS 5/2-103(a) (West 2000). When a defendant files a motion to transfer venue,it has the burden of proving that the plaintiff's selection of venue was improper. Weaver v.Midwest Towing, Inc., 116 Ill. 2d 279, 285, 507 N.E.2d 838, 840 (1987). "In doing so, thedefendant must set out specific facts, not conclusions, and show a clear right to the reliefasked for." Weaver, 116 Ill. 2d at 285, 507 N.E.2d at 840 (citing Taylor v. Southern Ry. Co.,350 Ill. 139, 143, 182 N.E. 805, 806-07 (1932), and Winn v. Vogel, 345 Ill. App. 425, 430,103 N.E.2d 673, 675 (1952)). "Any doubts arising from the inadequacy of the record willbe resolved against the defendant." Weaver, 116 Ill. 2d at 285, 507 N.E.2d at 840; Foutchv. O'Bryant, 99 Ill. 2d 389, 391-92, 459 N.E.2d 958, 959 (1984).

Defendant argues that venue is improper in Williamson County because defendantis a State governmental agency with its principal office located in Sangamon County. Defendant contends that the only possible basis for venue in Williamson County is underthe transactional portion of section 2-103(a) but that the transaction about which plaintiffcomplains did not occur in Williamson County. Plaintiff argues that Williamson County isa proper venue because a part of the transaction that led to the cause of action occurred inthat county. Plaintiff contends that the relief sought in its mandamus action arises out of itsinitial complaint concerning the conditions of the construction permit issued by defendantfor the hospital in Williamson County and that the outcome of the action will affect therights and conditions of employment of its represented employees in Williamson County.

Because plaintiff does not challenge defendant's assertion that it is a governmentalbody covered under section 2-103(a), we focus upon the transactional portion of section 2-103(a). " 'Transaction' has been defined to include every fact which is an integral part of acause of action." Kenilworth Insurance Co. v. McDougal, 20 Ill. App. 3d 615, 617, 313N.E.2d 673, 675 (1974). The term "transaction" should not be so narrowly interpreted toinclude only those immediate facts out of which the cause of action arose. SeeServiceMaster Co. v. Mary Thompson Hospital, 177 Ill. App. 3d 885, 890-91, 532 N.E.2d1009, 1012 (1988) (citing People ex rel. Carpentier v. Lange, 8 Ill. 2d 437, 441, 134 N.E.2d266, 267-68 (1956)). "Under transactional venue principles, two dependent variables mustbe analyzed to determine whether a particular venue is proper. Those variables are (1) thenature of the cause of action and (2) the place where the cause of action springs intoexistence." Lake County Riverboat L.P., 313 Ill. App. 3d at 952, 730 N.E.2d at 531. Somecourts have found that the place where a transaction occurs is the place where the partiesengaged in direct adversarial dealings (Williams v. Illinois State Scholarship Comm'n, 139Ill. 2d 24, 69, 563 N.E.2d 465, 485 (1990) (citing Winn, 345 Ill. App. at 431-32, 103 N.E.2dat 674)), while other courts have found the transactional place to be where an event or actoccurred that altered the parties' legal relationship. Williams, 139 Ill. 2d at 69, 563 N.E.2dat 485 (citing Christopher v. West, 345 Ill. App. 515, 528, 104 N.E.2d 309, 315 (1952)).

Defendant argues that we should consider only the interactions that occurred betweenplaintiff and itself in Cook County. Defendant contends that it is the dealings between theparties themselves, where they are adversarial, that properly determine transactional venueunder section 2-103(a), and not matters occurring between one of the parties and a thirdparty. While there are cases which hold that the term "transaction" must refer only to theparties' dealings, and not dealings between a party and a third party (American Oil Co. v.Mason, 133 Ill. App. 2d 259, 260-61, 273 N.E.2d 17, 18 (1971); Winn, 345 Ill. App. at 431-32, 103 N.E.2d at 676), those cases generally involve third-party dealings that arepreliminary to or an incidental part of the cause of action. Kenilworth Insurance Co., 20 Ill.App. 3d at 617, 313 N.E.2d at 675. However, third-party dealings that have a definite anddirect bearing on the cause of action may be considered a part of the transaction out of whichthe cause of action arose. Kenilworth Insurance Co., 20 Ill. App. 3d at 617, 313 N.E.2d at675; Bagarozy v. Meneghini, 8 Ill. App. 2d 285, 288-91, 131 N.E.2d 792, 793-95 (1955);First National Bank of Lacon v. Bauer Poultry Corp., 345 Ill. App. 315, 103 N.E.2d 160(1952).

Defendant's assertions are overly broad when applied to this case, where the third-party dealings with the hospital have a direct impact on the cause of action. Here, it wasdefendant's issuance of the construction permit followed by plaintiff's allegations of thehospital's noncompliance that constitute the events that altered the parties' legal relationship.These events definitely and directly bear on plaintiff's action in mandamus because plaintiffcould not otherwise rely upon the procedures guiding defendant to address such allegations. Although the procedures defendant allegedly violated in not conducting a contested case involved a transaction that occurred in Cook County, the procedures were to be performedfor the sole benefit of determining events and actions that occurred in Williamson County. See Frey Corp. v. Gilldorn Mortgage Midwest, Inc., 131 Ill. App. 3d 548, 554, 475 N.E.2d1100, 1104 (1985). These facts underlying plaintiff's cause of action are not incidental;they are central to plaintiff's cause.

The nature of plaintiff's cause of action is a complaint in mandamus. A complaintseeking the remedy of mandamus "must allege facts which establish a clear right to the reliefrequested, a clear duty of the respondent to act, and clear authority in the respondent tocomply with the writ." Noyola v. Board of Education of the City of Chicago, 179 Ill. 2d121, 133, 688 N.E.2d 81, 86 (1997). A mandamus action is an appropriate remedy to stopa clear abuse of discretion or to control the exercise of discretion in accordance with the law. Guzzo v. Snyder, 326 Ill. App. 3d 1058, 1063, 762 N.E.2d 663, 669 (2001). Here, plaintiffseeks relief that, if granted, would require defendant to conduct a contested case pursuantto section 10-25 of the Illinois Administrative Procedure Act (5 ILCS 100/10-25 (West2000)), to address plaintiff's initial allegations of the hospital's noncompliance with thepermit issued by defendant. Further, plaintiff notes that the outcome of the contested casecould result in the suspension or revocation of the construction permit for the hospital inWilliamson County.

Plaintiff cites to Iowa-Illinois Gas & Electric Co. v. Fisher, 351 Ill. App. 215, 114N.E.2d 581 (1953), as support for its argument that venue is proper in Williamson County. In Fisher, the plaintiff filed for a restraining order in Rock Island County against the IllinoisCommerce Commission (Commission) to prevent the enforcement of a rate reduction order. During the litigation, the Commission filed a motion to transfer venue to either Cook orSangamon County. The circuit court denied the Commission's motion to transfer venue. The Commission argued on appeal that Rock Island County was not a proper venue becauseno part of the transaction took place there. The appellate court affirmed the circuit court'sdenial of the Commission's motion to transfer venue. The court held: "There is no doubt thatthe [plaintiff] is doing business in Rock Island, and the order issued by the *** Commissionwould take effect in that county. [Therefore,] part of the transaction in the present case, outof which the cause of action arose, occurred in Rock Island [C]ounty ***." Fisher, 351 Ill.App. at 222, 114 N.E.2d at 583. The court noted, "It is where the shaft strikes [plaintiff],not where it is drawn, that counts." Fisher, 351 Ill. App. at 221-22, 114 N.E.2d at 583.

Defendant cites to Lake County Riverboat L.P. v. Illinois Gaming Board, 313 Ill.App. 3d 943, 730 N.E.2d 524 (2000), as support for its position that venue is not proper inWilliamson County. However, defendant's reliance on Lake County Riverboat L.P. ismisplaced because it is factually distinguishable from the case sub judice. In Lake CountyRiverboat L.P., the plaintiff, a prospective applicant for a casino gaming license in LakeCounty, brought suit against the Illinois Gaming Board (Board) in Lake County. The suitwas based on a constitutional challenge that sought a declaratory judgment and injunctiverelief. The Board moved to transfer to Cook County. The trial court ordered the casetransferred to Cook County, and the appellate court affirmed. The court held that LakeCounty was not a proper venue because (1) the plaintiff was not a licensed riverboat casinooperator in Lake County at the time it allegedly suffered injury, (2) it did not have anapplication pending before the Board at the time, (3) it had no direct dealings with the stateagency at the time it filed its cause of action, and (4) any action taken by the Board wouldnot occur in Lake County. Lake County Riverboat L.P., 313 Ill. App. 3d at 955-56, 730N.E.2d at 533.

In the instant matter, we are faced with facts more closely analogous to those inFisher, than those in Lake County Riverboat L.P. Here, plaintiff represented employees ofthe hospital at the time defendant allegedly violated the Illinois Administrative ProcedureAct. In addition, plaintiff had engaged in direct dealings with defendant at the time plaintifffiled its complaint for mandamus. Finally, if plaintiff is granted relief, any action taken bydefendant would, in purpose and effect, occur in Williamson County.

Thus, it is clear to us that the underlying facts are an integral part of plaintiff's causeof action, and the relief sought would take effect in the forum selected by plaintiff. Therefore, it is not unreasonable to find that a part of the transaction in the present case, outof which the cause of action arose, occurred in Williamson County.

Venue may properly lie in more than one jurisdiction. Patel v. Lacey, 203 Ill. App.3d 1048, 1049, 561 N.E.2d 455, 456 (1990). Though venue also would have been properin either Sangamon or Cook County, here we do not believe that defendant has satisfied itsburden of showing that plaintiff's selection of venue in Williamson County was improper. Given the purpose behind the venue statutes and the true nature of plaintiff's cause of action,we cannot hold that the circuit court abused its discretion in denying defendant's motion totransfer venue.

For the foregoing reasons, the judgment of the circuit court is affirmed.

Affirmed.

GOLDENHERSH and HOPKINS, JJ., concur.

Opinion Filed: July 1, 2002

Justices: Honorable Melissa A. Chapman, J.

Honorable Richard P. Goldenhersh, J., and

Honorable Terrence J. Hopkins, J.,

Concur

Attorneys James E. Ryan, Attorney General, State of Illinois, Joel D. Bertocchi, Solicitor

for General, Richard S. Huszagh, Assistant Attorney General, 100 West Randolph

Appellant Street, 12th Floor, Chicago, IL 60601

Attorney Patrick J. O'Hara, Cavanagh & O'Hara, 407 East Adams Street, P.O. Box 5043,

for Springfield, IL 62705

Appellee