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Piper Aircraft Co. v.
Reyno
454 U.S. 235 (1981)
Author: Jim
Facts: Plane manufactured by Piper
(D1), a Pennsylvania corp, crashed in Scotland. Parts of airplane
manufactured by Hartzell (D2), an Ohio corp., and plane
operated by Scottish corp and maintained by British Corp.
Ps sued D1 & D2 in California and the other corporation sued
in UK. D1 removed the case to Pennsylvania and filed for
dismissal for forum non conveniens.
Issue: Should the motion to
dismiss for forum non conveniens be granted?
Holding: Yes
Rationale: In a motion to
dismiss for forum non conveniens, a court should consider both
private and public interest factors. Private factors are
the relative ease of access to sources of proof; availability of
compulsory process for attendance of unwilling, and the cost of
obtaining attendance of willing, witnesses; possibility of view
of premises, if view would be appropriate to the action; and all
other practical problems that make trial of a case easy,
expeditious, and inexpensive. Pubic factors are the
administrative difficulties flowing from court congestion; the
local interest in having localized controversies decided at home;
the interest in having the trial of a diversity case in a forum
that is at home with the law that must govern the action; the
avoidance of unnecessary problems in conflict of laws, or in the
application of foreign law; and the unfairness of burdening
citizens in an unrelated forum with jury duty. In this
case, private factors favor Scotland because the wreckage of the
airplane is there and all of the witnesses to the crash are
there. Public factors also favor Scotland because since the
deceased were Scottish, Scotland has a strong interest in hearing
this case. Also, the fact that Scotland may be less
favorable to the plaintiffs does not provide a reason to dismiss
the motion of the defendants.
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