forum non conveniens doctrine (Massachusetts) · Go Syfert
← Massachusetts issues

forum non conveniens doctrine in Massachusetts

20 Massachusetts opinions name it 4 courts 1936–2024 1 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Universal Adjustment Corp. v. Midland Bank, Ltd., of Londongreen
mass · 1933 · cited in 6 Massachusetts opinions naming this issue, 1936–2018
2 sentences

2018The well-established common-law doctrine of forum non conveniens provides that, "where in a broad sense the ends of justice strongly indicate that the controversy may be more suitably tried elsewhere, then jurisdiction should be declined and the parties relegated to relief to be sought in another forum." Gianocostas , 450 Mass. at 723 , 881 N.E.2d 134 , quoting **473 Universal Adjustment Corp. v. Midland Bank, Ltd. , 281 Mass. 303 , 313, 184 N.E. 152 (1933).

2018The well-established common-law doctrine of forum non conveniens provides that, "where in a broad sense the ends of justice strongly indicate that the controversy may be more suitably tried elsewhere, then jurisdiction should be declined and the parties relegated to relief to be sought in another forum." Gianocostas , 450 Mass. at 723 , 881 N.E.2d 134 , quoting **473 Universal Adjustment Corp. v. Midland Bank, Ltd. , 281 Mass. 303 , 313, 184 N.E. 152 (1933).

36
Green v. Manhattanville Collegegreen
massappct · 1996 · cited in 3 Massachusetts opinions naming this issue, 1999–2011
2 sentences

2005However, “(o]f all of the factors to be considered in a forum non conveniens analysis, the availability of another suitable forum has been described as the most important.” Green v. Manhattanville College, 40 Mass.App.Ct. at 81 (internal quotations omitted).

1999See New Amsterdam Casualty Co. v. Estes, 353 Mass. 90, 95 (1967); Green v. Manhattanville College, 40 Mass.App.Ct. 76, 78 , cert. denied, 422 Mass. 1107 (1996) (same analysis under G.L.c. 223A, §5, as under common law doctrine of forum non conveniens).

23
Oxford Global Res., LLC v. Hernandezgreen
mass · 2018 · cited in 2 Massachusetts opinions naming this issue, 2019–2024
2 sentences

2024Oxford Global Resources, LLC v. Hernandez, 480 Mass. 462, 474 (2018).

2019See Oxford Global Resources, LLC v. Hernandez , 480 Mass. 462 , 472-473, 106 N.E.3d 556 (2018) (describing forum non conveniens); Pulte Computer Corp. vs .

22
Gulf Oil Corp. v. Gilbertred
scotus · 1947 · cited in 2 Massachusetts opinions naming this issue, 1995–2001
2 sentences

2001Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508-09 (1946). 1.

1995Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508 (1947).

22
Joly v. Albert Larocque Lumber Ltd.green
mass · 1986 · cited in 2 Massachusetts opinions naming this issue, 2003–2016
2 sentences

2016See also Joly v. Albert Larocque Lumber Ltd., 397 Mass. 43, 44 (1986) (doctrine of forum non conveniens must be applied with caution).

2003Joly, supra, 397 Mass, at 44.

12
New Amsterdam Casualty Co. v. Estesgreen
mass · 1967 · cited in 2 Massachusetts opinions naming this issue, 1995–1999
2 sentences

1999See New Amsterdam Casualty Co. v. Estes, 353 Mass. 90, 95 (1967); Green v. Manhattanville College, 40 Mass.App.Ct. 76, 78 , cert. denied, 422 Mass. 1107 (1996) (same analysis under G.L.c. 223A, §5, as under common law doctrine of forum non conveniens).

1995The Supreme Judicial Court in Estes also listed public interest factors to be considered under the doctrine of forum non conveniens, and noted that “(a]dministrative difficulties follow for courts when ligation is piled up in congested centers instead of being handled at its origin.” Id. at 95-96 .

12
W.R. Grace & Co. v. Hartford Accident & Indemnity Co.green
mass · 1990 · cited in 1 Massachusetts opinions naming this issue, 2019–2019
2 sentences

2019Co ., 407 Mass. 572 , 577, 555 N.E.2d 214 (1990) ("A decision whether to dismiss an action under the doctrine of forum non conveniens ... depends greatly on the specific facts of the proceeding before the court").

2019Co ., 407 Mass. 572 , 577, 555 N.E.2d 214 (1990) ("A decision whether to dismiss an action under the doctrine of forum non conveniens ... depends greatly on the specific facts of the proceeding before the court").

11
Warner-Lambert Co. v. Execuquest Corp.green
mass · 1998 · cited in 1 Massachusetts opinions naming this issue, 2011–2011
1 sentence

2011For the reasons set forth below, the Moving Party Reinsurers’ motions to dismiss are allowed pursuant to Mass.R.Civ.P. 12(b)(2). 2 BACKGROUND For the purposes of this motion, the court views the allegations of the complaint, as well as all inferences drawn therefrom, in the plaintiffs favor. 3 Warner-Lambert Co. v. Execuquest Corp., 427 Mass. 46, 47 (1998).

11
Minnis v. Peeblesgreen
massappct · 1987 · cited in 1 Massachusetts opinions naming this issue, 1999–1999
1 sentence

1999Defendants bear the burden of “showing circumstances so strongly in [their] favor that plaintiff! ] should be denied [her] right to bring suit in Massachusetts.” See Minnis v. Peebles, 24 Mass.App.Ct. 467, 473 (1987); Walton v. Harris, 38 Mass.App.Ct. 252, 258 , cert. denied, 420 Mass. 1102 (1995).

11
George E. Mercier v. Sheraton International, Inc., A/k/a, Itt-Sheraton International, Inc.green
ca1 · 1991 · cited in 1 Massachusetts opinions naming this issue, 1999–1999
1 sentence

1999See Mercier v. Sheraton Int’l, Inc., 935 F.2d 419, 423-24 (1st Cir. 1991), cert. denied, 508 U.S. 912 (1993).

11
Garrett v. United Statesgreen
scotus · 1993 · cited in 1 Massachusetts opinions naming this issue, 1999–1999
1 sentence

1999See Mercier v. Sheraton Int’l, Inc., 935 F.2d 419, 423-24 (1st Cir. 1991), cert. denied, 508 U.S. 912 (1993).

11
Appalachian Ins. Company v. Superior Courtgreen
calctapp · 1984 · cited in 1 Massachusetts opinions naming this issue, 1990–1990
2 sentences

1990Co. v. Superior Court of Los Angeles County, 162 Cal. App.3d 427, 438 (1984).

1990Co. v. Superior Court of Los Angeles County, 162 Cal. App. 3d 427, 438 (1984).

11
In re Certain Carriers Represented by Eastern, Western & Southeastern Carriers' Conference Committeesgreen
dcd · 1966 · cited in 1 Massachusetts opinions naming this issue, 1977–1977
1 sentence

1977Even so, the court made it clear that it was not proposing to take over the general enforcement of the award, but was reserving the right to “invoke the doctrine of forum non conveniens.” Id. at 534.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Pinson v. Potter neutral
mass · 1937
2 sentences

1967Order overruling “Answer in Abatement and Plea to the Jurisdiction” affirmed. 1 This right by the statute is subject “to all defences and rights of counterclaim, recoupment or set-ofE to which the defendant would have been entitled had the action been brought in the name of the assignor . . ..” 2 Milliken v. Meyer, 311 U. S. 457, 463 . 3 Although the issue is not presented whether the doctrine of forum non conveniens should be applied, see Pinson v. Potter, 298 Mass. 109, 114 , we note that the facts do not suggest that jurisdiction should be declined on this ground.

1964In Pinson v. Potter, 298 Mass. 109 , a suit brought in the District Court of Springfield, a Texas plaintiff sued a Connecticut defendant for injuries suffered in an automobile accident in Connecticut; our Supreme Court ruled that the motion to dismiss was allowed by the court because of lack of jurisdiction and not because it invoked the doctrine of forum non conveniens.

21964–1967
Gianocostas v. Interface Group-Massachusetts, Inc. green
mass · 2008
1 sentence

2018The well-established common-law doctrine of forum non conveniens provides that, "where in a broad sense the ends of justice strongly indicate that the controversy may be more suitably tried elsewhere, then jurisdiction should be declined and the parties relegated to relief to be sought in another forum." Gianocostas , 450 Mass. at 723 , 881 N.E.2d 134 , quoting **473 Universal Adjustment Corp. v. Midland Bank, Ltd. , 281 Mass. 303 , 313, 184 N.E. 152 (1933).

12018–2018
Bushkin Associates, Inc. v. Raytheon Co. green
mass · 1985
2 sentences

2018Under Massachusetts choice of law principles, if the agreement here were silent as to choice of law, the rights of the parties would be "determined by the local law of the state which, with respect to that issue, has the most significant relationship to the transaction and the parties." Bushkin Assocs., Inc. v. Raytheon Co. , 393 Mass. 622 , 632, 473 N.E.2d 662 (1985), quoting Restatement (Second) of Conflict of Laws § 188(1) (1971).

2018Under Massachusetts choice of law principles, if the agreement here were silent as to choice of law, the rights of the parties would be "determined by the local law of the state which, with respect to that issue, has the most significant relationship to the transaction and the parties." Bushkin Assocs., Inc. v. Raytheon Co. , 393 Mass. 622 , 632, 473 N.E.2d 662 (1985), quoting Restatement (Second) of Conflict of Laws § 188(1) (1971).

12018–2018
Walton v. Harris green
massappct · 1995
1 sentence

1999Defendants bear the burden of “showing circumstances so strongly in [their] favor that plaintiff! ] should be denied [her] right to bring suit in Massachusetts.” See Minnis v. Peebles, 24 Mass.App.Ct. 467, 473 (1987); Walton v. Harris, 38 Mass.App.Ct. 252, 258 , cert. denied, 420 Mass. 1102 (1995).

11999–1999
Rokeby-Johnson v. Kentucky Agricultural Energy Corp. green
nyappdiv · 1985
1 sentence

1990That court said that "the traditional criteria utilized in the forum non conveniens analysis must defer to [what the New York court called] a freely negotiated, rational forum selection clause the enforcement of which will not work undue hardship on any party." That court was dealing, however, with a service of suit clause, identical to the one in this case ( id. at 338 ), and not with a clause dictating a specific forum in which any case would *582 have to be decided.

11990–1990
Milliken v. Meyer green
scotus · 1941
1 sentence

1967Order overruling “Answer in Abatement and Plea to the Jurisdiction” affirmed. 1 This right by the statute is subject “to all defences and rights of counterclaim, recoupment or set-ofE to which the defendant would have been entitled had the action been brought in the name of the assignor . . ..” 2 Milliken v. Meyer, 311 U. S. 457, 463 . 3 Although the issue is not presented whether the doctrine of forum non conveniens should be applied, see Pinson v. Potter, 298 Mass. 109, 114 , we note that the facts do not suggest that jurisdiction should be declined on this ground.

11967–1967

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 223A, § 5 (11) MA § Mass. Gen. Laws ch. 223A, § 3 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 259 (1948–2026) PA 113 (1959–2026) TX 110 (1960–2025) CA 109 (1953–2026) NY 105 (1943–2025) FL 88 (1954–2024) AL 74 (1990–2025) DE 68 (1961–2026) NJ 48 (1954–2024) OH 46 (1936–2025) CT 44 (1985–2020) MI 31 (1973–2020) DC 31 (1957–2015) WA 28 (1959–2026) MO 25 (1958–2023) WV 24 (1963–2026) MA 20 (1936–2024) MT 18 (1961–2017) GA 18 (1956–2025) LA 17 (1971–2010) MN 16 (1954–2019) MS 14 (1968–2020) TN 12 (1989–2025) MD 10 (1995–2025) ME 10 (1989–2020) NM 10 (1979–1998) KY 9 (1981–2023) OR 9 (1968–2025) IN 9 (1985–2019) CO 9 (1972–2019) OK 8 (1974–2014) RI 8 (2001–2016) UT 7 (1950–2023) SD 6 (1990–2015) VA 6 (1991–2013) AR 6 (1957–2010) NV 6 (2013–2022) AK 6 (1985–2024) NC 5 (2014–2020) WY 4 (1999–2024) KS 4 (1962–1990) IA 3 (1995–2018) NH 3 (1988–2007) AZ 3 (1978–2024) ND 2 (2009–2009) VI 2 (2023–2023) HI 2 (1948–1998) NE 2 (2007–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check