Piper Aircraft Co. vs. Reyno Digest

Piper Aircraft Co. v. Reyno

Forum non-conveniens

Facts:

1. Reyno was the representative of the estates of citizens and decedents who were residents of Scotland. The decedents were killed in a plane crash (mechanical failure) in Scotland during a chartered flight of an aircraft manufactured by the petitioner. 

2. Petitioner is a company in Pennsylvania, while Hartzel, the one maintaining the propeller was from Ohio. The aircraft was registered in United Kingdom. It was operated by a UK company owned by McDonald (of Scotland). Meanwhile, the  plane pilot who also died is of Scottish descent.

3. The UK government conducted an investigation. The representatives of five (5) passengers who perished filed an action against Piper Corp and Hartzel in California while the survivors filed a separate action in UK against Air Navigation, McDonald and the pilot's estate. Hartzel was properly served with process. The petitioner Piper and Hartzell both moved to dismiss on ground of forum non-conveniens (FNC).

Issue: Whether or not the court should dismiss on ground of FNC

HELD:

YES. The court held that the private and public factors favored Scotland. When an alternative forum has jurisdiction to hear a case and when trial in the chosen forum would establish oppressiveness and vexation to a defendant, or when the chosen forum is inappropriate because of considerations affecting the courts own administrative and legal concerns, the court may in the exercise of sound discretion dismiss the case by applying the list of private and public interest factors. The wreckage of the plane was in Scotland (private) while Scotland had greater interest in hearing the case that concerns Scottish citizens (public).

The private factors include; relative ease of access to evidence, attendance of witnesses, cost of attendance, viewing the scene and other practical matters. While public factors include: administrative difficulties of courts, interest in having local controversies adjudicated at home, interest in trial in a forum familiar with the law governning the action, avoidance of unnecessary problems in the CFLm unfairness of burdening the citizens in an unrelated forum with jury duty.