Piper Aircraft Co. v. Reyno

Facts

In July 1976 a small commercial aircraft, a twin-engine Piper Aztec, crashed in the Scottish highlands on a charter flight from Blackpool to Perth. The pilot and five passengers died. All the passengers were Scottish, and so were their heirs. Piper Aircraft built the plane in Pennsylvania, and Hartzell Propeller built the propellers in Ohio. The plane was registered in Great Britain, owned and maintained by Air Navigation and Trading Co., and operated by McDonald Aviation, a Scottish air taxi service. Both companies were organized in the United Kingdom. The British Department of Trade investigated. A Review Board found no evidence of defective equipment and said pilot error may have contributed. In July 1977 a California probate court appointed Gaynell Reyno, a legal secretary to the lawyer who brought the suit, to represent the passengers' estates. She sued Piper and Hartzell in a California state court for wrongful death, claiming negligence and strict liability (liability without proof of fault). She admitted she filed in the United States because its law was more favorable to her. Scottish law does not recognize strict liability, and it lets only the decedents' relatives sue for wrongful death. The relatives filed a separate suit in the United Kingdom against Air Navigation, McDonald and the pilot's estate.

Issues

1. Can a plaintiff defeat a forum non conveniens dismissal merely by showing that the law of the alternative forum is less favorable to her than the law of the court where she sued?
2. Did the District Court abuse its discretion in weighing the private and public interest factors and in giving a foreign plaintiff's choice of forum less deference?

Holding

The possibility that Scottish law was less favorable to the plaintiff did not bar dismissal, because the Scottish remedy was not so inadequate as to be no remedy at all. The District Court properly applied the presumption in favor of Reyno's forum choice with less than maximum force, because the real parties in interest were foreign, and it did not act unreasonably in finding that private and public interests favored trial in Scotland.