Piper Aircraft Co. v. Reyno

In 1976, a small commercial aircraft crashed in Scotland, killing the pilot and five passengers. The deceased were all Scottish citizens and residents. The plane was manufactured in Pennsylvania by Piper Aircraft Co. (Piper) (defendant), and the propellers were manufactured in Ohio by Hartzell Propeller, Inc. (Hartzell) (defendant). Gaynell Reyno (plaintiff), the administratrix of the passengers' estates, filed wrongful-death actions against Piper and Hartzell in California state court, alleging negligence and strict liability. Reyno admitted to filing the action in the United States because its laws were more favorable to her case than those of Scotland. Piper and Hartzell removed to federal district court in California and then sought a transfer to the Middle District of Pennsylvania. The California district court granted the motions. After both cases were moved to federal district court in Pennsylvania, Piper and Hartzell sought to dismiss the case on grounds of forum non conveniens. The Pennsylvania district court granted the motions, citing the discretion courts have to dismiss a case if an alternative forum has jurisdiction to hear the case and if trial in the chosen forum would be burdensome to the defendant. The United States Court of Appeals for the Third Circuit reversed on the ground that dismissal for forum non conveniens is not appropriate if the law of the alternative forum is less favorable to the plaintiff. The United States Supreme Court granted certiorari.