Piper Aircraft Co. v. Reyno

Brief Fact Summary.

An airplane crash in the Scottish highlands killed the pilot and five passengers. Respondent, as administratrix of the estates of five passengers killed, brought a California state court negligence and strict liability action against Petitioner, the aircraft’s manufacturer, and the manufacturer of the plane’s propellers.  The survivors of the five decedents also filed a separate action in the United Kingdom against the owner of the airplane, its operator, and the pilot’s estate. Petitioner removed the action to federal court in California; the court granted Petitioner’s  motion to transfer the proceeding to federal district court in Pennsylvania. Petitioner subsequently moved to dismiss on the ground of forum non conveniens. The district court granted the motion; the court of appeals reversed. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

The possibility of an unfavorable change of the law does not bar dismissal on the grounds of forum non conveniens.

Facts.

Respondent, as administratrix of the estates of five decedents killed on a charter flight that crashed in the Scottish highlands, brought a California state court negligence and strict liability action  against Petitioner, the aircraft’s manufacturer, and the manufacturer of the plane’s propellers. The five decedents’ survivors filed a separate action in the United Kingdom against the owner of the airplane, its operator, and the pilot’s estate, who were not parties to the United States litigation. The administratrix filed the action in the United States because laws regarding liability, capacity to sue and damages were more favorable to her position than those of Scotland. Petitioner removed the action to federal court in California; the court granted Petitioner’s  motion to transfer the proceeding to federal district court in Pennsylvania. After the matter was transferred, Petitioner moved to dismiss on the ground of forum non conveniens. The district court granted the motion; the United States Court of Appeals for the Third Circuit reversed. The Supreme Court granted certiorari.

Issue.

Did the Court of Appeals err in reversing the district court’s decision to grant Petitioner’s motion to dismiss based on forum non conveniens?

Held.

Yes. The Court of Appeals erred in holding that a plaintiff may defeat a motion to dismiss on the grounds of forum non conveniens merely by showing that the substantive law that would be applied in the alternative forum is less favorable to the plaintiffs; the district court did not otherwise abuse its discretion in applying the private and public interests.

Dissent.

Justice Stevens

The dissent argued that, having decided that dismissal is permissible even if the other forum’s law is less favorable, the Court should have remanded that matter to the court of appeals for further consideration of whether the district court correctly decided that Pennsylvania was not a convenient forum.

Discussion.

Dismissal on the grounds of forum non conveniens is not automatically barred where the law of the alternative forum is less favorable to the plaintiff than the law of the forum chosen by the plaintiff; the possibility of an unfavorable change in the applicable law should not, in and of itself, bar dismissal. Additionally, the district court did not otherwise abuse its discretion in applying the private and public interests to determine whether dismissal was warranted based on forum non conveniens grounds.