Piper Aircraft v Reyno
454 U S 235 [1981]
Author:- Sam Biers

Relevant Facts: A small commercial plane crashed in Scotland carrying five passengers and a pilot who were all killed.  The decedents and heirs are all Scottish.  There were no eyewitnesses.  The aircraft was manufactured in PA by Petitioner, Piper.  The propellers were manufactured by Hartzell in OH.  The aircraft was own and operated by UK companies.  A British report found no evidence of defective equipment and indicated that pilot error may have contributed.  The pilot had his license for three months prior.  A CA probate ct appointed Respondent Reyno as administratrix of the estates of the passengers. She was legal secretary of their survivor’s attorney

Legal Issue(s): Whether Pls can defeat a motion to dismiss on ground of forum non conveniens by showing that the substantive law that would be applied in the alternative forum is less favorable to the Pl than that of the chosen forum; and whether the D Ct acted unreasonably in concluding that fewer evidentiary problems would be posed if the trial were held in Scotland; and whether the district court properly determined that the public interest factors favored trial in Scotland?

Court’s Holding: No, and No

Procedure: Action filed in CA by Reyno; Dfs removed to Fed D Ct CA then successfully sought transfer to Pennsylvania F D Ct; Df Motion to dismiss (Forum Non Conveniens) granted, Pl Appealed; Ct of App Reversed and Remanded; S. Ct  Reversed

Law or Rule(s): When an alternative forum has jurisdiction to hear a case and when trial in the chosen forum would establish oppressiveness and vexation to a Df out of proportion to Pl’s convenience, or when the chosen forum is inappropriate b/c of considerations affecting the ct’s own administrative and legal problems, the ct may in the exercise of sound discretion dismiss the case by applying the list of private and public interest factors.

Court Rationale:  Under Gilbert, supra, dismissal will ordinarily be appropriate where trial in the plaintiff's chosen forum imposes a heavy burden on the defendant or the court, and where the plaintiff is unable to offer any specific reasons of convenience supporting his choice. Nor may an analogy be drawn between forum non conveniens dismissals and transfers between federal courts

as precluding a transfer if it resulted in a change in the applicable law.

In analyzing the private interest factors, the District Court did not act unreasonably in concluding that fewer evidentiary problems would be posed if the trial were held in Scotland, a large proportion of the relevant evidence being located there. The District Court also correctly concluded that the problems posed by the petitioners' inability to implead potential Scottish third-party defendants--the pilot's estate, the plane's owners, and the charter company--supported holding the trial in Scotland.

The District Court's review of the factors relating to the public interest was also reasonable. Even aside from the question whether Scottish law might be applicable in part, all other public interest factors favor trial in Scotland, which has a very strong interest in this litigation. The accident occurred there, all of the decedents were Scottish, and apart from petitioners, all potential parties are either Scottish or English.

Plaintiff’s Argument: American citizens have an interest in ensuring that American manufacturers are deterred from producing defective products and that additional deterrence might be obtained by trial in the United States where they could be sued on the basis of both negligence and strict liability.

Defendant’s Argument: The oppressiveness imposed against the Dfs by forcing them to defend a case in American cts when all the evidence and witnesses are located in Scottland is contrary to established law.