Forum Non Conveniens and American Plaintiffs in the Federal Courts

In Gulf Oil Corp. v. Gilbert,' the Supreme Court held that federal courts have discretion to dismiss suits properly within their jurisdiction under the doctrine of forum non conveniens. 2 The doctrine makes dismissal appropriate whenever another forum exists where the suit may be brought, and either the plaintiff's choice of forum is so vexatious or oppressive to the defendant "as to be out of all proportion to plaintiff's convenience," '4 or "trial in the chosen forum [is] inappropriate because of considerations affecting the court's own administrative and legal problems."Although the number of cases to which the doctrine is applicable has been significantly reduced since the Gulf Oil decision by judicial 6 and legislative 7 developments, it has still been invoked to deprive plaintiffs of an American forum. 8 The courts remain di-1 330 U.S. 501 (1947). 2 Forum non conveniens does not apply unless jurisdiction and venue are proper in the court in which the action is originally brought.Id.