Summary of Piper Aircraft Company v. Reyno, U.S. Supreme Court (1981)
Cause of action: The following is a cause of action for negligence, which turned into a cause of action regarding forum non conveniens as it pertains to citizens of two nations.
Procedural History: After a CA probate court appointed DF the administratrix for the families of the five decedents of a plane crash, she filed separate wrongful-death claims against PL’s Piper and Hartzell (plane manufacturers) in Superior Court of CA for negligence and strict liability. Survivors of the 5 dead passengers filed a separate action in the UK against Air Navigation, McDonald (operator), and the pilot’s estate. Suit in CA was made for reasons of more lenient laws regarding capacity to sue, damages and liability were better in the U.S., as Scottish law has no strict liability in tort, and wrongful-death claims are only good for “loss of support and society.”
On petitioners’ motion, suit removed to U.S. District Court for the Central District of CA, where Piper moved for transfer to U.S. District Court for the Middle District of PA pursuant to 1404(a). Hartzell moved to dismiss for lack of PJ or to transfer. DC transferred case to Middle District.
After transferred, Hartzell & Piper moved to dismiss on ground of forum non conveniens. D.C. Granted these motions, relying on balancing test from Gulf Coast Oil Corp. v. Gilbert & Koster v. Lumbermans (private interest factors vs. public interest factors). D.C. held the trial would be much easier to hold in Scotland, as the plane, navigation and parties were all in Scotland, as opposed to respondent’s contention the plane, testing, design, and manufacture were all in the states. Court of Appeals rejected this test, holding the latter factors above were more important and reversed. Supreme Court reversed Court of Appeals (affirming in effect the D.C.).
Facts: Plane crash involving American-made and designed plane in Scotland, which killed five people. DF is the administratrix.
Issue(s): Under federal rules of civil procedure, do DF plane manufacturer and plane designer have the right to have their cases tried in a Scotland court when the accident happened there under a cause of action regarding forum non conveniens?
Under federal rules of civil procedure, do PL’s have the right to have a case removed to U.S. District Court for the same forum non conveniens when the plane was manufactured and designed in the states?
Court’s Rationale/Reasoning: The private interest factors involved here are more suited for trying in Scotland. The accident occurred there, as well as the ability to interview critical witnesses and experts would be better served by trying in Scotland. By simply going by the Court of Appeals argument that b/c damages and rules were better in the States in unfounded, as such an idea is:
(a) not the true purpose of forum non conveniens, as retaining flexibility within the judicial system is;
(b) it would make non conveniens virtually useless, b/c anyone could use the rule;
(c) dismissals would be rarely proper, unless
(d) a taxing analysis were done discussing the possible outcomes, remedies and decisions which would result from each possible venue; and finally
(e) the caseload in the States would increase dramatically, as parties would always go after the deep pockets, and would backlog the system with more cases and more taxing analyses
This is not to say if a result would be so disproportionate that the case could not go back to the States, but the rule is a rule of flexibility, not simply convenience. Scotland’s remedy is okay in comparison. There was no abuse of discretion here. Scotland doesn’t have overwhelming connections, but they are better served over there. Witnesses could be called more conveniently over there to settle technical issues. Pilot’s estate and McDonald navigation are crucial to PL’s suit, and trying them over in the States would in essence be taking two trips to do the same thing in one suit. Piper’s BOP would be to show someone else created the accident by looking for indemnity, and it could be better served in one system. Public interest right is also on the mark as far as the D.C. goes, and the American interest is insignificant in comparison to those in Scotland overall.
Rule: Balancing test for forum non-conveniens: public interest factors for trying court in disputed forum versus private interest in the same concern.
Holding: Yes. The balancing test applied by the District Court was more in favor of how the forum non conveniens should be applied; based on the accident occurring in Scotland, the passengers being from Scotland, and the laws which governed the action are from Scotland, the case should be tried in the UK.
No. Trying the case in the U.S. would require much more judicial legwork than simply holding court in Scotland. The laws may be different there, but the remedy is not substantially different, and D.C.’s test for application of the rule is the better use of the rule.