Piper Aircraft v. Reyno – Case Brief Summary
Summary of Piper Aircraft v. Reyno, 454 U.S. 235 (1981).
A plane manufactured by Piper Aircraft (D1), a Pennsylvania corporation, crashed in Scotland. Parts of the airplane were manufactured by Hartzell (D2), an Ohio corporation. Reyno (P) was appointed administrator for the families of five UK citizens involved in a plane crash in their suit against the defendants for negligence and strict liability. The families of the dead passengers sued Air Navigation, the operator of the plane (McDonald), and the estate of the deceased pilot in a separate action in the UK.
The complaint was filed in California by Reyno. The defendants removed to federal district court in California and then successfully sought transfer to Pennsylvania district court. The defendants’ motion to dismiss on forum non conveniens grounds was granted and Reyno appealed. The court of appeals reversed and remanded.
- Can Reyno prevail on the defendants’ motion to dismiss on the grounds of forum non conveniens by showing that the substantive law that would be applied in the alternative forum is less favorable to Reyno than that of the chosen forum?
- Did the district court act unreasonably in concluding that fewer evidentiary problems would arise if the trial were held in Scotland, and in determining that the public interest factors favored trial in Scotland?
Holding and Rule
1) No. 2) No.
When an alternative forum has jurisdiction to hear a case and when trial in the chosen forum would establish oppressiveness and vexation to a defendant out of proportion to the plaintiff’s convenience, or when the chosen forum is inappropriate because of considerations affecting the court’s own administrative and legal concerns, the court may in the exercise of sound discretion dismiss the case by applying the list of private and public interest factors.
In a motion to dismiss for forum non conveniens, a court should consider both private and public interest factors.
Private factors include the relative ease of access to sources of proof, availability of compulsory process for the attendance of unwilling witnesses, the cost of attendance of witnesses, the possibility of viewing the scene if appropriate to the action, and other practical matters related to making the trial easy, expeditious, and inexpensive.
Public factors include administrative difficulties of the courts, interest in having local controversies adjudicated at home, the interest in having the trial in a forum that is familiar with the law governing the action, the avoidance of unnecessary problems in conflict of laws or the application of foreign law, and the unfairness of burdening citizens in an unrelated forum with jury duty.
The court held that private factors favored Scotland because the wreckage of the plane and witnesses were there. The court also held that public factors favored Scotland because Scotland had a greater interesting in hearing a case that concerned Scottish citizens. The court also held that the fact that Scotland might have been less favorable to Reyno did not provide a reason to dismiss the defendants’ motion.
Reversed in favor of the defendants.
See Helicopteros Nacionales de Colombia v. Hall for a law school civil procedure case brief involving a wrongful death action arising from a helicopter crash in a foreign country.