Piper Aircraft Co. v. Reyno

Brief Fact Summary.

Plaintiff sues in American for a Scottish accident involving all Scottish citizens because the law in America is more favorable.

Synopsis of Rule of Law.

A plaintiff may not defeat a motion to dismiss on the grounds of forum non conveniens merely by showing that the substantive law of the alternate forum is less favorable to them than the present forum.

Facts.

A commercial aircraft crashed in Scotland killing the six people, all Scottish citizens and residents. Plaintiff Reyno, the administrix of the estates of the decedents brought suit in California state court against Defendants Piper and Hartzell alleging negligence and strict liability, admitting that this forum had more favorable laws. Defendants removed the case to federal court and then sought transfer to the Middle District of Pennsylvania, which the California district court granted. Once in Pennsylvania, Defendants sought to dismiss the case based on forum non conveniens. The Pennsylvania district court granted the motion, citing the discretion that courts have to dismiss the case if a different forum that has jurisdiction and if defending in the forum would be burdensome to the defendant. The United States Court of Appeals for the Third Circuit reversed, holding that forum non conveniens was inappropriate if the law of the alternate forum was less favorable to the plaintiff. The United States Supreme Court granted certiorari.

Issue.

May a plaintiff survive a motion to dismiss on the grounds of forum non conveniens merely by showing that the substantive law that would be applied in the alternate forum is less favorable to them than the present forum?

Held.

No, a plaintiff may not survive a motion to dismiss on the grounds of forum non conveniens merely by showing that the substantive law that would be applied in the alternate forum is less favorable to them than the present forum.The judgment of the appellate court is reversed.

Discussion.

1. The possibility of unfavorable law should not be a factor considered in a forum non conveniens inquiry.
2. Allowing this inquiry would draw more foreign plaintiffs to file suit in the United States which would result in congested courts.
3. However, an unfavorable change in the law may be considered in a forum non conveniens inquiry if the remedy available in the alternate forum is so inadequate that it is essentially no remedy at all.
4. The main goal of a forum non conveniens inquiry is to ensure the trial is convenient.
5. Therefore a resident or citizen plaintiff is given greater deference if they have chosen their home forum because it is assumed the forum is convenient.
6. This assumption is not the same for a foreign plaintiff.
7. Forum non conveniens determination is at the discretion of the trial court and is reviewed for clear abuse of discretion.
8. In Gulf Oil Corp. v. Gilbert the court outlined private interest and public interest factors that affect the convenience of a forum.
9. While the remedies in Scotland may be less than those available in America, the remedies in Scotland are not entirely nonexistent.
10. Regarding private interests, although the records of the design and manufacture of the plane and propellers is in America, a greater amount of the evidence is in Scotland.
11. The district court was correct in stating that it would be difficult for Defendants to implead potential third-party defendants in an American trial because the potential third-party defendants are located in Scotland.
12. As for the public interest factors, the district court determined that if the suit were brought in Pennsylvania, Pennsylvania law would apply to Defendant Piper and Scottish law to Defendant Hartzell, which would be confusing to a jury.
13. Scotland also has a strong interest in trying this case because the accident occurred in Scottish airspace and all the decedents were Scottish.
14. Therefore the district court did not abuse its discretion in deciding that public and private interests support moving the trial to Scotland.
15. The judgment of the appellate court is reversed.