Piper Aircraft Co. v. Reyno

Piper Aircraft Co. v. Reyno, 454 US 235 - Supreme Court 1981 Facts: A small commercial aircraft crashed in the Scottish highlands during the course of a charter flight from Blackpool to Perth. The pilot and five passengers were killed instantly. The aircraft was a twin-engine Piper Aztec that Piper Aircraft Co. in Pennsylvania manufactured. The propellers were manufactured by Hartzell Propeller, Inc. in Ohio. The British Department of Trade investigated the accident shortly after it occurred. found no evidence of defective equipment and indicated that pilot error may have contributed to the accident. The pilot, who had obtained his commercial pilot's license only three months earlier, was flying over the high ground at an altitude considerably lower than the minimum height required by his company's operations manual. Plaintiff’s Argument: Reyno candidly admits that the action against Piper and Hartzell was filed in the United States because its laws regarding liability, capacity to sue, and damages are more favorable to her position than those of Scotland. Procedural History: Reyno sued Piper and Hartzell in the Superior Court of California. The suit was removed to the United States District Court for the Central District of California. Then the suit was transferred to the United States District Court for the Middle District of Pennsylvania. both Hartzell and Piper moved to dismiss the action on the ground of forum non conveniens. The District Court granted these motions. On appeal, the United States Court of Appeals for the Third Circuit reversed and remanded for trial. The Supreme Court granted a writ of certiorari. Issue: May a plaintiff defeat a motion to dismiss for forum non convenience merely on the basis that the law of the alternative forum is far less advantageous? Rule: The plaintiff may not defeat a motion to dismiss for forum non conveniens merely by showing that the substantive law that would be applied in the alternative forum is less favorable to him than that of the present forum. Holding: Reversed. Reasoning: The possibility of an unfavorable change in the law in Scotland should not, by itself, bar dismissal. The court held that plaintiffs may not defeat a motion to dismiss on the ground 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 than that of the chosen forum, since the possibility of a change in substantive law should ordinarily not be given conclusive or even substantial weight in the forum non conveniens inquiry. In this case the proper forum was Scotland given that fewer evidentiary problems would be posed if the trial were held in Scotland; the inability to implead potential third party defendants clearly supported holding the trial in Scotland; and public interest favored trial in Scotland, the accident having occurred in its air space, all the decedents being Scottish, and apart from the manufacturers, all potential plaintiffs and defendants being either Scottish or English.