Monday, April 29, 2013

Piper Aircraft Co. v. Reyno case brief

Piper Aircraft Co. v. Reyno case brief
102 S. Ct. 252, 70 L. Ed. 2d 419 (1981)

CASE SYNOPSIS: Petitioner manufacturer appealed a decision from the United States Court of Appeals for the Third Circuit, which reversed a district court's grant of petitioner's motion to dismiss respondent representative's wrongful-death action on the ground of forum non conveniens.

FACTS: Respondent's decedents died in an aircraft in the Scottish highlands. All the decedents were Scottish residents, as were their heirs. As the decedents' personal representative, respondent filed suit against petitioner in the United States because petitioner manufactured the aircraft in Pennsylvania and because the law was more favorable there. Petitioner wanted to litigate the tort action in Scotland, and filed to dismiss the action in Pennsylvania. A district court dismissed the action, but the lower appellate court reversed the district court's decision.

On appeal, the court reversed, finding the district court had not abused its discretion in dismissing the matter. It noted that the possibility of an unfavorable change in the law in Scotland should not, by itself, bar dismissal. There usually was a strong presumption, the court explained, in favor of a plaintiff's choice of forum. However, that presumption applied with less force when a plaintiff or real party in interest was foreign. It was more convenient for a plaintiff to choose its home forum. Therefore, when a foreign plaintiff chose a United States forum, the presumption was less reasonable.

CONCLUSION: The court reversed the decision of the lower appellate court and affirmed the decision of the district court, finding that the possibility of an unfavorable change in the law should not, by itself, bar dismissal.

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