Can a Case Be Transferred If the Public Interest Factors Weigh Strongly In Favor of the Place As a Preferable Forum ?
In Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981), the United States Supreme Court reversed a ruling by the court of appeals and granted defendants' request for a change of forum from Pennsylvania, where plaintiff filed the case, to Scotland, where the airplane crash took place. Piper, 454 U.S. at 261, 70 L. Ed. 2d at 439, 102 S. Ct. at 268-69.
Although the court did reason that if defendants could show that the accident was caused by pilot error, rather than a design defect, they would be relieved of liability, this was an isolated sentence in the court's overall analysis.
The court began its analysis of the private interest factors by noting that "particularly with respect to the question of relative ease of access to sources of proof, the private interests point in both directions." Piper, 454 U.S. at 258, 70 L. Ed. 2d at 419, 102 S. Ct. at 269.
The court ruled in favor of transfer, however, because the public interest factors weighed strongly in favor of Scotland as a preferable forum. Piper, 454 U.S. at 259-261.