Should the potential for unfavorable changes in foreign law preclude dismissal on forum non conveniens grounds when foreign plaintiffs sue American defendants in U.S. federal court?

A small commercial aircraft manufactured by Piper Aircraft Co. in Pennsylvania, with propellers made by Hartzell Propeller, Inc. in Ohio, crashed in Scotland. The accident resulted in the deaths of all five Scottish passengers and the pilot. Gaynell Reyno, a legal secretary unrelated to the victims, was appointed administratrix of the estates. Reyno filed wrongful death actions against Piper and Hartzell in California state court.

The case was subsequently removed to federal court and transferred to the Middle District of Pennsylvania. Piper and Hartzell filed motions to dismiss on forum non conveniens grounds, arguing that Scotland was the more appropriate forum for the litigation. The district court granted the motion to dismiss. However, the Court of Appeals for the Third Circuit reversed this decision.

Plaintiffs initially filed the case in California state court. The defendants subsequently removed the case to federal court and successfully petitioned for its transfer to the Middle District of Pennsylvania. In the district court, the defendants moved to dismiss the case on forum non conveniens grounds, which the court granted. The plaintiffs then appealed this dismissal to the Court of Appeals for the Third Circuit. The Third Circuit reversed the district court's decision, ruling in favor of the plaintiffs. Following this reversal, the defendants petitioned the Supreme Court for certiorari to review the Court of Appeals' decision, which the Supreme Court granted.

(Marshall, J.)

No. The possibility of an unfavorable change in law should not, by itself, preclude dismissal on forum non conveniens grounds when foreign plaintiffs sue American defendants in U.S. federal courts. Giving substantial weight to potential changes in law would effectively nullify the doctrine of forum non conveniens. The analysis of private and public interest factors under the Gilbert test remains the proper framework for determining forum non conveniens dismissals. A foreign plaintiff's choice of forum deserves less deference than that of a domestic plaintiff. The need to apply foreign law favors dismissal, as it places an unnecessary burden on U.S. courts to interpret and apply unfamiliar legal principles.

The doctrine of forum non conveniens serves the important purpose of allowing courts to decline jurisdiction when the chosen forum would be oppressive or vexatious to the defendant or inappropriate due to practical considerations. Overemphasizing potential changes in law would undermine this doctrine's flexibility and purpose. The Gilbert test provides a comprehensive framework for evaluating the appropriateness of a forum, considering factors such as access to evidence, availability of witnesses, and the local interest in deciding localized controversies. These factors, rather than speculative changes in law, should guide the forum non conveniens analysis.

Furthermore, the principle of international comity supports giving proper weight to a foreign country's interest in applying its own laws to disputes involving its citizens or occurring within its borders. U.S. courts should not readily assume that foreign legal systems are inadequate or that their laws are unfavorable, as doing so would show disrespect for other nations' sovereignty and judicial systems. The focus should remain on the convenience and interests of the parties and the courts, rather than on comparing the substantive law of different jurisdictions.

Concurrence/Dissent (White, J.) Concurred in Parts I and II of the Court's opinion. The possibility of an unfavorable change in law should not bar forum non conveniens dismissal. The district court's analysis in these sections was reasonable and sound. However, I dissent from Part III. The Court should not have addressed the issues in that section, as they were unnecessary to resolve the case at hand and may have broader implications that require more careful consideration.

Dissent (Stevens, J.) The Court should have simply answered the certified question in the negative and remanded the case to the Court of Appeals for further consideration. By going beyond this scope, the majority has unnecessarily expanded the ruling and potentially created unintended consequences for future cases. The prudent approach would have been to limit our decision to the specific question presented and allow the lower court to apply that answer in its further deliberations.

Dissent (Brennan, J.) Concurred with the majority opinion without providing a separate written opinion.