Piper Aircraft Co. v. Reyno case brief
1981
Facts: Case brought in California State Court; the case was removed to District Court for Central District of California. Piper then moved to transfer case to District Ct of Pennsylvania under 1404 (a). Reyno properly served process on Hartzell, bringing him into District Ct of Pennsylvania. Both Hartzell and Piper moved for forum non-conveniens which were granted using balancing test set forth in the previous case (Gilbert.) Said connections outside the U.S. are overwhelming, Reyno represents out of country plaintiffs, and Piper could not implead Scottish companies so case dismissed. The third circuit reversed and remanded trial where dismissal is never appropriate where the law of alt. forum is less favorable to the plaintiff and where District Ct abuses its discretion with Gilbert analysis. SCOTUS reversed again. Judgment for defendants; cannot sue in the U.S.
Reasoning: Justice Marshall: Does not make sense when using Court of appeals logic. Court of appeals main pt was that the defendants could not remove to Scotland because Scotland did not have substantive rules as beneficial to plaintiff as the U.S. Said that applying this test will not work since courts will always need to compare two states remedies and laws to determine which court had better laws and if the case can be dismissed. The doctrine is designed to help courts avoid complex exercises in comparative law. District court was right in saying that less evidentiary problems would occur in Scotland and that a foreign plaintiff does not have as much power to sue in the U.S. as does a citizen. Need to apply foreign law generally should lead towards dismissal.
** Court must determine whether an alternative forum exists at outset of the case. Sometimes the remedy offered is clearly unsatisfactory so that another forum is not an adequate alternative.
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Facts: Case brought in California State Court; the case was removed to District Court for Central District of California. Piper then moved to transfer case to District Ct of Pennsylvania under 1404 (a). Reyno properly served process on Hartzell, bringing him into District Ct of Pennsylvania. Both Hartzell and Piper moved for forum non-conveniens which were granted using balancing test set forth in the previous case (Gilbert.) Said connections outside the U.S. are overwhelming, Reyno represents out of country plaintiffs, and Piper could not implead Scottish companies so case dismissed. The third circuit reversed and remanded trial where dismissal is never appropriate where the law of alt. forum is less favorable to the plaintiff and where District Ct abuses its discretion with Gilbert analysis. SCOTUS reversed again. Judgment for defendants; cannot sue in the U.S.
Reasoning: Justice Marshall: Does not make sense when using Court of appeals logic. Court of appeals main pt was that the defendants could not remove to Scotland because Scotland did not have substantive rules as beneficial to plaintiff as the U.S. Said that applying this test will not work since courts will always need to compare two states remedies and laws to determine which court had better laws and if the case can be dismissed. The doctrine is designed to help courts avoid complex exercises in comparative law. District court was right in saying that less evidentiary problems would occur in Scotland and that a foreign plaintiff does not have as much power to sue in the U.S. as does a citizen. Need to apply foreign law generally should lead towards dismissal.
** Court must determine whether an alternative forum exists at outset of the case. Sometimes the remedy offered is clearly unsatisfactory so that another forum is not an adequate alternative.
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