Review Questions Module 2

profilehomework97
CaseBriefontheWilsonV.PiperAircraftCorporationHELPFUL.docx

Case Brief Template

Case Name & Citation

Piper Aircraft Co. v. Reyno, 454 U.S. 235, 102 S. Ct. 252 (1981)

Facts

In July 1976, an airplane was involved in an accident in the Scottish Highlands while on a charter flight from Blackpool to Perth, killing the pilot and five passengers instantly. The aircraft was a Piper Aztec manufactured by Piper Aircraft Co. in the U.S. state of Pennsylvania, and Hartzell Propeller, Inc. manufactured the propellers in the U.S. state of Ohio. A British Department of Trade found no evidence of defective equipment and indicated that pilot error may have caused the accident. A California probate court appointed respondent Gaynell Reyno administratrix of the estates of the five passengers. She did not know nor was she related to any of the decedents, she was merely the legal secretary to the attorney who filed this lawsuit. Reyno admitted the choice of the United States as a venue was more favorable to her case.

Procedural History

Several days after her appointment, Reyno commenced separate wrongful-death actions against Piper and Hartzell in the Superior Court of California, claiming negligence and strict liability. The defendants first removed to federal district court in California invoking diversity jurisdiction. Piper then sought to transfer under 28 U.S.C. § 1404(a) to the Middle District of Pennsylvania on grounds of convenience because Piper engaged in business in Pennsylvania. Hartzell moved to dismiss for want of personal jurisdiction, or in the alternative to transfer the case to the Middle District of Pennsylvania under 28 U.S.C. § 1631, where Hartzell's business with Piper supported jurisdiction. The district court transferred. With both cases now moved to federal district court in Pennsylvania, both defendants then sought to dismiss the case on grounds of forum non conveniens. The District Court granted these motions in October 1979. The Third Circuit reversed, on the ground that dismissal for forum non conveniens is never appropriate where the law of the alternative forum is less favorable to the plaintiff.

Issue(s)

1. What kind of analysis should a court do to determine if a motion to dismiss based upon forum non conveniens should be granted?

2. Should the possible change in substantive law be given weight in a forum non conveniens action?

Holding

· The US Supreme Court reversed, and dismissed the case.

The US Supreme Court found that the private interest factors involved here are more suited for trying in Scotland.  The accident occurred there, as well as the ability to interview critical witnesses and experts would be better served by trying in Scotland.

The Court had already established that the argument that the case should be held in the US because damages and rules were better in the US than in the UK was not convincing (see Canada Malting Co. v. Patterson Steamships, Ltd. (285 US 413 (1932))).

Rule of Law

If the remedy provided by the alternative forum is so clearly inadequate or unsatisfactory that it is no remedy at all, the unfavorable change in law may be given substantial weight; the district court may conclude that dismissal would not be in the interests of justice.

Reasoning

· An alternative forum existed in Scotland.

Witnesses are in Scotland.

Scotland has an interest in the case.

· P is a representative of foreign citizens and residents seeking a forum in the US because of the more liberal rules concerning products liability law.

· If upheld, all sorts of litigation would flow into the US.

· Gilbert addressed the fact that US courts should not usually have to apply foreign law. Applying foreign law is confusing for courts and juries. "The need to apply foreign law points towards dismissal."

· Because the central purpose of any forum non conveniens inquiry is to ensure that the trial is convenient, a foreign P's choice deserves less deference.

· The forum non conveniens determination is committed to the sound discretion of the trial court; it may be reversed only when there has been a clear abuse of discretion.

Disposition

Reversed

Comments

Choosing a particular forum because the law is more favorable to the plaintiff cannot be given any substantial weight under a forum non conveniens analysis. Although the general rule is that a court should not dismiss a case on grounds of forum non conveniens unless there is an alternate forum in which the plaintiff can pursue a remedy, this rule only requires that the plaintiff be able to file a proper lawsuit in that alternate forum.