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Piper Aircraft Co. v. Reyno

(1981)

Supreme Court of the United States - 454 U.S. 235, 102 S.Ct. 252, 70 L.Ed.2d 419

tl;dr:

An airplane crash which occurred in Scotland may be dismissed from a US forum on the basis of forum non conveniens.

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Case Summary

In 1981, the Supreme Court decided the Piper Aircraft Co. v. Reyno case, which centered on a dispute between foreign plaintiffs and American defendants regarding the legal concept of forum non conveniens. The plaintiffs sought wrongful death damages after a fatal airplane crash in Scotland, alleging manufacturing defects in the plane and its propellers. They filed their lawsuit in California, while the defendants argued that Scotland was the more appropriate venue due to location, evidence, and witness availability.

The district court granted the defendant's motion to dismiss based on forum non conveniens. However, the appeals court later reversed this decision, citing insufficient consideration of the plaintiff's choice of forum. The Supreme Court eventually overruled the appeals court, maintaining that the district court had properly considered all relevant factors and that the plaintiffs could not defeat a motion to dismiss solely based on less favorable laws in the alternative forum.

This case established an essential guideline for forum non conveniens decisions involving foreign plaintiffs and forums, emphasizing consistency with the Federal Employers' Liability Act and international comity. The case also revealed differing opinions among the justices on balancing plaintiffs' choice of forum and defendants' interest in a fair trial. The majority opinion, with two separate concurrences, focused on maintaining uniform liability rules, while the dissenting opinion advocated for a more flexible approach based on fairness and policy considerations.

ICRAIssue, Conclusion, Rule, Analysis for Piper Aircraft Co. v. Reyno

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Facts & HoldingPiper Aircraft Co. v. Reyno case brief facts & holding

Facts:Piper Aircraft Co (Defendant) manufactured an aircraft in Pennsylvania with...

Holding:The less favorable law in the alternative forum is not...

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Piper Aircraft Co. v. Reyno | Case Brief DeepDive
Majority opinion, author: Justice Marshall
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The case involves a wrongful-death action brought by the representative of Scottish citizens killed in an air crash against Piper Aircraft Co. and Hartzell Propeller, Inc. The District Court granted the petitioners' motion to dismiss the case on the ground of forum non conveniens, but the United States Court of Appeals for the Third Circuit reversed the decision. The Supreme Court concluded that the District Court did not abuse its discretion in dismissing the case, despite the possibility of an unfavorable change in law. The aircraft involved in the crash was manufactured in Pennsylvania by Piper Aircraft Co. and the propellers were manufactured in Ohio by Hartzell Propeller, Inc. The aircraft was owned and maintained by Air Navigation and operated by McDonald Aviation, both of which were organized in the United Kingdom. The wreckage of the plane is currently in a hangar in Farnsborough, England. The British Department of Trade conducted an investigation into the air crash and suggested that mechanical failure in the plane or propeller may have caused the accident. Hartzell Propeller requested a review of the report by a three-member Review Board, which found no evidence of defective equipment and suggested that pilot error may have contributed to the accident. The administratrix of the estates of the five passengers filed separate wrongful-death actions against Piper and Hartzell in the Superior Court of California, claiming negligence and strict liability. The suit was removed to the United States District Court for the Central District of California and then transferred to the Middle District of Pennsylvania. The District Court's dismissal of the case on the ground of forum non conveniens was not an abuse of discretion, as Scottish law does not recognize strict liability in tort and permits wrongful-death actions only when brought by a decedent's relatives, who may sue only for "loss of support and society."

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Opinion (Concurring-in-part-and-dissenting-in-part), author: Justice White
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Justice White agrees with the first two parts of the Court's opinion, but disagrees with the third part. He is in the minority with Justices Brennan and Stevens who also do not want to discuss the issues in Part III.

Dissenting opinion, author: Justice Stevens
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The dissent written by Justice Stevens and joined by Justice Brennan disagrees with the Court's decision to limit the review to whether foreign plaintiffs can defeat a motion to dismiss on the grounds of forum non conveniens by showing that the substantive law to be applied in the district court is more favorable than that of their own nation's courts. The dissent argues that such a motion should not be denied whenever the alternate forum's law is less advantageous to the case than that of the district court's. The dissent suggests remanding the case to the Court of Appeals for further consideration of whether Pennsylvania is a convenient forum to hear a claim against a Pennsylvania company that a flawed plane was manufactured and designed in Pennsylvania. The lower court's alleged miscalculation was its failure to look into whether the substantive law that would be applied in Pennsylvania is suitable for the foreign plaintiffs.

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