Piper Aircraft v. Reyno
454 U.S. 235 (1981)
- A Piper Aircraft crashed in Scotland, killing the pilot and five passengers, all Scottish citizens, were killed.
- At the time the plane was under Scottish Air Traffic Control
- The Airplane and propellers were manufactured by petitioners in PA and OH.
- The plane was operated by a Scottish taxi service and companies organized in the UK. The wreckage is in a UK hangar.
- The British Department of Trade investigation attributed the accident to mechanical failure in the plane and propeller.
- A 3-member review board did not find evidence of defective equipment and attributed it to pilot error. The pilot had been flying lower than the minimum height.
- Respondent has no relation to the victims, she is a legal secretary of the attorney that filed the suit.
- Reyno brought wrongful death actions in US District court.
- Defendants moved to dismiss on grounds of forum non conveniens. Granted
- Reversed by Court of Appeals
Contentions of parties:
- Reyno: Damages more favorable in US because Scotland does not have strict liability, Plane and propeller were manufactured and designed in US.
Whether a US Court can deny a motion of forum non conveniens on the ground that the alternative forum is less advantageous to the plaintiff and offers less damages.
A motion to dismiss on ground of forum non convenience can not be defeated by a plaintiff by showing that the law in the alternative forum is less favorable.
To defeat a motion of dismissal on forum non conveniens must be balanced according to the private and public interest factors.
Rule of Law:
|Private interest factors||Public Interest Factors|
Private interest factors:
- Plane is in Scotland, easier for fact-finder to go to plane and not plane to fact finder.
- Expensive to bring witnesses to US, US courts may have no power to subpoena a witness in Scotland.
- Plaintiffs: Airplane and propeller manufactured in the US- if there is a design defect, they can find liability in the defendants. Witnesses and documents of design of plane are all in US, but it is easier to fly these witnesses and documents instead of the entire wreckage- RELATIVE.
Public Interest Factors:
- Burden of jury duty: jury have no interest about Scottish matters that do not pertain to them.
- Local interest: even though the US has an interest in keeping US products safe, but it was Scottish citizens, plane flown in UK, all leads to a local matter in Scotland.
- Amount of judicial time and resources outweighs US’s local interest.
Even though there are some factors toward not granting forum non convenience, it would take too much time of the court’s money and time to try in the US.