Case brief summary
When deciding whether to dismiss a case because another country's court is more convenient, courts should not refuse dismissal just because the plaintiff would get a worse legal outcome there.
Facts
A small American-made plane crashed in Scotland, killing the pilot and passengers. The victims' representative sued the American manufacturers in US court instead of Scotland because American law favored her claims more.
Procedural history
The trial court dismissed the case, finding Scotland more convenient. The appeals court reversed, saying dismissal is never allowed if the plaintiff loses access to more favorable law.
Issue
Can a plaintiff block dismissal to a foreign court just by showing that country's laws are less favorable, and did the trial court properly weigh convenience factors?
Holding
Facing less favorable foreign law alone does not block dismissal, and the trial court reasonably decided Scotland was the better place for trial.
Reasoning
Allowing less favorable law alone to block dismissal would let plaintiffs always choose American courts, making the convenience doctrine pointless. The trial court reasonably found most witnesses and evidence were in Scotland, which had a strong interest in the case.
Opinions
Majority (Marshall): A worse foreign law alone cannot block dismissal for inconvenient forum, and the trial judge reasonably found Scotland the proper place for this trial.
Concurrences (White): Agrees that unfavorable foreign law alone does not bar dismissal, but would not have reached the separate question of whether the trial court properly weighed the convenience factors.
Dissent (Stevens, joined by Brennan): Agrees foreign law alone does not bar dismissal, but would send the case back to the lower appeals court to decide the convenience question rather than deciding it directly.