PIPER AIRCRAFT COMPANY V. REYNO
454 U.S. 235 (1981)
NATURE OF THE CASE: This was an appeal from a dismissal under forum non-conveniens.
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.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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