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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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