Saul Munoz Sibaja, Rafaela Arrieta Porra, et al. v. Dow Chemical Co., et al.

Summary

The Eleventh Circuit affirmed dismissal of a diversity action under the federal doctrine of forum non conveniens. The court held that applying the federal forum non conveniens rule, rather than Florida's rule, did not violate the Erie doctrine because forum non conveniens is a venue-related exercise of the federal court's inherent power, not a substantive rule of decision.

Holdings

1. A federal district court sitting in diversity may apply the federal forum non conveniens doctrine rather than the forum state's contrary rule.
2. The dismissal did not violate Erie even though Florida law would have permitted the plaintiffs to litigate to judgment while federal law sent them to Costa Rica.

Questions Presented

1. Whether the Erie doctrine required a federal district court sitting in diversity to apply Florida's forum non conveniens rule rather than the federal forum non conveniens doctrine.
2. Whether applying the federal forum non conveniens doctrine, despite its effect on the litigation's outcome, constituted application of a state substantive rule in violation of Erie.

Disposition

affirmed