## Facts

- A Piper Aztec aircraft crashed in Scotland during a charter flight, killing the pilot and five passengers.
- The passengers, their heirs, and next of kin were Scottish citizens and residents; the aircraft was owned, operated, and registered in Great Britain.
- Piper manufactured the aircraft in Pennsylvania; Hartzell manufactured the propellers in Ohio.
- British authorities investigated and reported no evidence of defective equipment, suggesting pilot error as a possible cause.
- A California court appointed Gaynell Reyno, a California legal secretary with no relationship to the decedents, as administratrix to bring suit.
- Reyno sued Piper and Hartzell in California, asserting negligence and strict products liability, and acknowledged filing in the United States because it provided more favorable rules on liability, standing, and damages than Scotland.
- Scottish law did not provide strict products liability in this setting and restricted wrongful-death damages more than U.S. law.

## Issues

1. Whether a plaintiff can defeat forum non conveniens dismissal solely by showing the alternative forum’s substantive law is less favorable.
2. Whether the district court abused its discretion in dismissing for forum non conveniens after weighing private and public interest factors and identifying Scotland as the appropriate forum.

## Decision

- The Supreme Court reversed the court of appeals and reinstated the district court’s forum non conveniens dismissal in favor of litigation in Scotland.
- A less favorable change in substantive law in the alternative forum does not, by itself, bar dismissal.
- An alternative forum is ordinarily adequate unless its remedy is so inadequate or unsatisfactory that it is effectively no remedy at all.
- Reduced deference applies when the real parties in interest are foreign, weakening the presumption in favor of the chosen U.S. forum.
- The court of appeals erred by reweighing the balancing factors; forum non conveniens determinations are reviewed only for clear abuse of discretion.

## Legal Principles

- Forum non conveniens permits dismissal when an adequate alternative forum exists and private and public interest factors favor the alternative forum.
- Comparative disadvantage in the alternative forum’s substantive law is ordinarily not given conclusive or substantial weight in the forum non conveniens analysis.
- The “adequate alternative forum” requirement is satisfied unless the alternative forum offers no meaningful remedy.
- A foreign plaintiff’s forum choice receives less deference than a domestic plaintiff’s home-forum choice.
- Appellate courts review forum non conveniens dismissals for abuse of discretion and should not substitute their judgment for the trial court’s factor-balancing.

## Conclusion

The Court held that forum non conveniens dismissal to Scotland was proper despite Scotland’s less favorable liability and damages rules, because Scotland provided a meaningful remedy and the district court reasonably found that key evidence, witnesses, local interests, and likely governing law pointed to Scotland; the appellate court was required to defer absent clear abuse of discretion.


Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981)