Piper Aircraft Co. v. Reyno
454 U.S. 235, 102 S. Ct. 252, 70 L.Ed. 2d 419 (1981)

  • Five UK citizens were killed in a plane crash in Scotland. The administrator of their estates, Reyno, sued Piper (who made the plane in Pennsylvania) and Hartzell (who made the engines in Ohio) in California State Court for negligence and strict liability.
    • Relatives of the five dead passengers separately sued Air Navigation, McDonald (operator), and the pilot’s estate in a UK court.
    • Reyno admitted that she brought suit in California because the US had more lenient laws regarding capacity to sue, damages and liability than the UK.
      • UK law has no strict liability in tort, and wrongful-death claims are only good for  “loss of support and society.”
    • Reyno argued that she had standing to sue in California State court because she was a California resident.
  • Piper had the case moved to a Federal Court in California, and then, successfully moved to have the case transferred to a Federal Court in Pennsylvania pursuant to 28 USC § 1404(a).
    • According to 28 USC § 1404(a), you have to use California law, regardless of where you move the case to.  However, California’s conflict principles states that if the case is moved to another State, and there is a conflict of laws, you have to use that State’s law.
      • For example, if it’s a case of speeding, it’s really appropriate to use the speed limit of the place you were speeding, not in the place where the trial is being held.
    • So, under California law, you have to use Pennsylvania Tort law, because under California law you use the law of where the defendant is.  In Pennsylvania, their conflict principles state that you should use the law of where the tort occurred.  So, for the Pennsylvania plaintiffs, you have to apply Scottish law!
      • This conflict of laws principle is an issue-by-issue determination.  This starts to get complicated really fast.
  • After it was transferred to the Federal Court in Pennsylvania, Hartzell & Piper moved to dismiss on ground of forum non conveniens.
    • Forum non conveniens means that the chosen forum is not where the case should be heard.  In this case, Piper argued that the case was more appropriately heard in a UK Court.
  • The Pennsylvania Federal Trial Court granted this motion.  Reyno appealed.
    • The Pennsylvania Federal Trial Court held the trial would be much easier to hold in Scotland, as the plane, navigation and parties were all in Scotland, as opposed to respondent’s contention the plane, testing, design, and manufacture were all in the states.
  • The Federal Appellate Court reversed.  Piper appealed.
    • The Appellate Court based their decision on the grounds that dismissal should be barred when the law of the alternate forum is less favorable to the plaintiff than the forum the plaintiff chose.
      • Scottish law is less favorable to plaintiffs than Pennsylvania law.  But isn’t less favorable to the plaintiff, more favorable to the defendant?  Why should we favor one side over the other?
  • The US Supreme Court reversed, and dismissed the case.
    • The US Supreme Court found that the private interest factors involved here are more suited for trying in Scotland.  The accident occurred there, as well as the ability to interview critical witnesses and experts would be better served by trying in Scotland.
    • The Court had already established that the argument that the case should be held in the US because damages and rules were better in the US than in the UK was not convincing (see Canada Malting Co. v. Patterson Steamships, Ltd. (285 US 413 (1932))).
    • This was a clear case of forum shopping.
      • Now, under 28 USC § 1332, the executor of an estate takes on the citizenship of the decedent.  This is specifically to stop this type of forum shopping.