Piper Aircraft Co. v. Reyno
Citation: 454 U.S. 235 (U.S. Supreme Court, 1981)
Facts
A commercial aircraft manufactured by Piper (a Pennsylvania company) crashed in Scotland, killing Scottish citizens. The administrator of the estates of the victims filed suit in California (later transferred to Pennsylvania) against Piper and Hartzell Propeller (an Ohio company). Scotland offered a less favorable legal standard for plaintiffs, so litigation was brought in the United States.
Issue
Whether a plaintiff’s choice of forum should be given less deference when dismissal for forum non conveniens is sought, and whether the fact that the foreign forum provides a less favorable remedy is relevant to the forum non conveniens analysis.
Holding
The Supreme Court held that the district court had properly dismissed on forum non conveniens grounds. A plaintiff’s choice of forum receives less deference when the plaintiff is foreign, and the unfavorability of the alternative forum’s law is not a relevant factor in the forum non conveniens analysis.
Rule
Forum non conveniens allows dismissal when a more convenient forum exists. Courts balance private interest factors (access to evidence, compulsory process for witnesses, cost of obtaining attendance) and public interest factors (court congestion, local interest in the controversy, familiarity with applicable law). Plaintiff’s choice is entitled to less deference when the plaintiff is foreign. An alternative forum is adequate as long as the defendant is amenable to process there, even if the law is less favorable to the plaintiff.
Significance
Piper Aircraft is the leading forum non conveniens case, establishing that the availability of a less favorable legal regime in the alternative forum is not a bar to dismissal. It defines the private and public interest factors and the treatment of foreign plaintiffs.