Civil Procedure Keyed to Cound
Piper Aircraft Co. v. Reyno
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There was a plane crash in Scotland, where five citizens of Scotland were killed. The aircraft was manufactured in Pennsylvania by Piper Aircraft Company (Defendant) and the propellers were made in Ohio by Hartzell Propeller, Inc. (Defendant). The plane was registered in Great Britain and owned and operated by people from the United Kingdom. The wreckage was in England. An investigation conducted by The British Department of Trade concluded that there was no evidence of defective equipment and that the crash was probably due to pilot error. Reyno, Plaintiff, a legal secretary for the attorney of the decedents’ survivors, was appointed administratrix of the decedents’ estate by a California probate court. Plaintiff commenced separate wrongful death actions against the Piper and Hartzell in California Superior Court, claiming negligence and strict liability. They also filed suit in the United Kingdom against the owner and operator. Plaintiff admits that she filed suit in the United States because of its laws regarding liability and capacity to sue. Defendant filed motion to remove to the District Court in California which was granted. Piper moved to transfer to the District Court in Pennsylvania. Hartzell moved to dismiss for lack of personal jurisdiction or, in the alternative, to transfer. The District Court quashed service and transferred the case to Pennsylvania. Plaintiff then served Hartzell with process in the District Court in Pennsylvania. Defendants moved to dismiss for forum non conveniens. The District Court of Pennsylvania granted the motions based on the analysis articulated in [Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 67 S.Ct. 839, 91 L.Ed. 1055 (1947)], namely that: 1) An alternative forum existed in Scotland; 2) The plaintiff only filed in the U.S. for the favorable law; 3) There were overwhelming connections with Scotland; 4) Witnesses and evidence were beyond the reach of compulsory process.; 5) All of Defendants’ witnesses are in Great Britain; 6) There should be only one trial to preserve judicial expense and avoid the risk of inconsistent verdicts; 7) Scottish law would apply to Hartzell, and Pennsylvania law would apply to Piper, which would be excessively confusing for a jury; 8) The jurors have little connection to the controversy; 9) Scotland has a substantial interest in the outcome of litigation. The Circuit Court reversed and remanded District Court’s decision. It held that the District Court abused its discretion when using the Gilbert analysis. In addition, the court baed its argument on several additional factors: (1) dismissal is never appropriate where the law of the alternative forum is less favorable to Plaintiffs; (2) Plaintiffs’ choice of forum deserves substantial weight even though they are non-residents; (3) Defendants did not prove that all their witnesses were in Great Britain; (4) Defendants’ inability to implead other defendants would be burdensome but not unfair; (5) viewing the wreckage and Scottish topography was not that significant; (6) application of foreign law does not require dismissal; (7) Pennsylvania and Ohio would be the governing law anyway, because these states have the greatest policy interests; and finally (8) a dismissal for forum non conveniens should not result in a change in the applicable law, just a change in the location of the trial. The Supreme Court read this holding to mandate that dismissal is automatically barred if it would lead to a change in the applicable law unfavorable to the plaintiff.
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