Piper Aircraft Co. v. Reyno
70 L. Ed. 2d 419 · Supreme Court of the United States · 1982
Facts
After a plane crash in Scotland killed Scottish citizens, their estates' representative, a U.S. citizen, sued the U.S. manufacturers in a U.S. federal court, seeking more favorable U.S. product liability laws. The District Court dismissed the case on forum non conveniens grounds, finding Scotland an adequate alternative forum, but the Court of Appeals reversed, holding that dismissal is automatically barred if the alternative forum's law is less favorable to the plaintiff.
Issue
Does the possibility of an unfavorable change in substantive law in an alternative forum automatically bar dismissal on grounds of forum non conveniens? Did the District Court abuse its discretion in applying the forum non conveniens balancing test?
Holding
No, the possibility of an unfavorable change in law does not automatically bar dismissal on forum non conveniens grounds. The Supreme Court reversed the Court of Appeals, finding that the District Court did not abuse its discretion in dismissing the case.
Rule
The possibility of an unfavorable change in substantive law should not ordinarily be given conclusive or substantial weight in a forum non conveniens inquiry, unless the alternative forum's remedy is so inadequate as to be no remedy at all. A foreign plaintiff's choice of forum is entitled to less deference than a resident plaintiff's choice.
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