Piper Aircraft Company v. Reyno

454 U.S. 235 (1981)

Facts

A small commercial aircraft crashed in Scotland during a charter flight. The pilot and five passengers were killed. When the plane crashed, it was registered in Great Britain, operated by a Scottish taxi service, subject to Scottish air traffic control, and was filled with nothing but Scottish residents. A California probate court appointed Gaynell Reyno (P) administratrix of the estates of the five passengers. P was in fact a legal secretary to the attorney who eventually filed the lawsuits. The accident occurred in Scotland and all the victims resided there. The evidence from the crash investigation showed that pilot error might have been the primary cause of the accident but that mechanical failure could have played a role. P filed suit in California because the laws regarding liability were more favorable than those of Scotland. The survivors of the five passengers also filed suit in the United Kingdom. The suit was removed to the United States District Court for the Central District of California. D then moved for transfer to the United States District Court for the Middle District of Pennsylvania, pursuant to 28 U.S.C. § 1404(a). It was transferred to Pennsylvania. D then moved to dismiss under forum non-conveniens with Scotland being the proper forum. P opposed the motion because of the advantages of American laws and this was readily admitted to the court. The district court granted the motion; the court used the balancing test set forth in Gulf Oil Corp. v. Gilbert with the 'private interest factors' affecting the litigants' convenience and the 'public interest factors' affecting the forum's convenience, the District Court concluded that Scotland was the appropriate forum and the only substantive argument against dismissal was that the law of Scotland was less favorable. The court of appeals reversed; dismissal is never appropriate when the law of the alternative forum is less favorable to the plaintiff. The Supreme Court granted certiorari.