Wheeler v. Societe Nationale Des Chemins De Fer Francais
1952 U.S. Dist. LEXIS 2337, 108 F. Supp. 652 (1952)
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Rule of Law:
A plaintiff's choice of forum should rarely be disturbed unless the balance of conveniences is strongly in favor of the defendant. An American court may decline jurisdiction over a suit brought by a U.S. citizen only if allowing the case to proceed would result in an injustice to the defendant.
Facts:
- Plaintiff, a resident of Florida, was allegedly injured as a result of defendant's negligence.
- Defendant is a French corporation that was operating a locomotive.
- The accident occurred at La Pallice, France, on August 20, 1947.
- At the time of the accident, Plaintiff was accompanied by six fellow crew members who were witnesses to the event.
- All six of the Plaintiff's eyewitnesses reside in the United States.
- The Defendant's witnesses, who would testify as to the terrain and safety precautions, reside in France.
Procedural Posture:
- Plaintiff, a Florida resident, commenced a personal injury action against the defendant, a French corporation, in a U.S. District Court on November 29, 1951.
- Thirteen days prior, on November 16, 1951, the Plaintiff had instituted a similar action in France.
- The Defendant moved to dismiss the U.S. action on two grounds: (a) forum non conveniens, arguing the proper forum is France, and (b) the action is barred by the statute of limitations.
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Issue:
Does the doctrine of forum non conveniens require the dismissal of a personal injury action brought by a U.S. citizen against a foreign corporation in a U.S. court, when the injury occurred in the foreign country but key eyewitnesses for the plaintiff reside in the U.S.?
Opinions:
Majority - Noonan, District Judge
No. The doctrine of forum non conveniens does not require dismissal in this instance. While a court must weigh the relative advantages and obstacles to a fair trial, the plaintiff's choice of forum should rarely be disturbed unless the balance is strongly in favor of the defendant. Here, while the defendant's witnesses are in France, the plaintiff's six eyewitnesses are in the United States. Although the defendant will be inconvenienced, this burden is not unconscionable. The court reasoned that an American court should not deny jurisdiction to a U.S. citizen unless it finds that an injustice would result. Considering that one party will inevitably be inconvenienced, and weighing the burdens on each, the court concluded that retaining the action would not be an injustice and the plaintiff's choice of forum should be respected.
Analysis:
This decision reinforces the strong deference courts give to a plaintiff's choice of forum, particularly when the plaintiff is a U.S. citizen suing in a U.S. court. It establishes that a defendant's claim of inconvenience, even when supported by the location of its witnesses and the accident site, is insufficient to warrant dismissal on forum non conveniens grounds if the plaintiff also has critical witnesses in the chosen forum. The ruling clarifies that the defendant must demonstrate not just inconvenience, but a level of hardship that would constitute an 'injustice' to overcome the presumption in favor of the plaintiff's chosen forum.
