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Piper Aircraft Co. v. Reyno

Supreme Court of the United States · 1981 · Civil Procedure

Civil Procedureforum non conveniensprivate interest factorspublic interest factorstransferforum non conveniensGilbert factorsprivate interests

Facts

A plane manufactured in Pennsylvania with propellers manufactured in Ohio crashed in Scotland during a charter flight, killing a Scottish pilot and five Scottish passengers. The decedents, their heirs, relevant maintenance and training witnesses, and much of the accident-related evidence were in Great Britain, and the wreckage was in England. Respondent, a California-appointed administratrix who was not related to the decedents, sued Piper and Hartzell in the United States because American law was more favorable, especially because Scottish law did not recognize strict liability and limited wrongful-death recovery. Piper and Hartzell agreed to submit to Scottish jurisdiction and waive any statute of limitations defense there, then moved to dismiss on forum non conveniens grounds.

Issue

Whether a plaintiff can defeat a forum non conveniens dismissal merely by showing that the alternative forum's substantive law is less favorable than the chosen forum's law. Also, whether the District Court abused its discretion in dismissing this case in favor of Scotland after balancing the relevant private and public interest factors.

Rule

The possibility of an unfavorable change in substantive law should ordinarily not be given conclusive or even substantial weight in the forum non conveniens inquiry and does not by itself bar dismissal. A plaintiff's choice of forum is entitled to less deference when the plaintiff or the real parties in interest are foreign, and dismissal is proper when an adequate alternative forum exists and the Gilbert private and public interest factors reasonably point to trial in the alternative forum. Only when the alternative forum's remedy is so clearly inadequate or unsatisfactory that it is no remedy at all may the unfavorable change in law be given substantial weight.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Families of three Chilean tourists sue Summit Forge Equipment, a fictional manufacturer based in Ohio, in federal court in Cleveland after a bus fire in Chile allegedly caused by a defective fuel valve made in Ohio. Summit agrees to submit to Chilean jurisdiction and waive any limitations defense there. Chilean law allows negligence claims but does not recognize strict products liability and caps certain wrongful-death damages.

How should the federal court treat the plaintiffs' argument that dismissal must be denied because Chilean law is less favorable than Ohio law?

Explanation. The majority held that the possibility of an unfavorable change in substantive law should ordinarily receive neither conclusive nor substantial weight in the forum non conveniens analysis. A less favorable foreign law does not itself bar dismissal. The key questions are whether there is an adequate alternative forum and whether the Gilbert private and public interest factors point there. A forum becomes inadequate only in the rare case where the remedy is so unsatisfactory that it is no remedy at all.