The Supreme Court of Missouri recently decided a case that significantly changes the handling of motions for transfer for improper venue under Missouri’s Supreme Court Rule 51.045. The case is State ex rel. Kansas City Southern Railway Co. v. Nixon, 282 S.W.3d 363 (Mo.banc 2009) (Overview/Summary). In this case, the Court affirmed the circuit court’s granting of a motion for leave to amend the petition to add an additional defendant, thereby correcting the problem with venue, and denial of a motion for transfer for improper venue. To understand how this case changes proceedings under Rule 51.045, some history is necessary.