Gulf Oil Corp. v.

Gilbert
330 U.S. 501
10 March 1947
Justice Jackson

Facts:
Respondent Gilbert resides in Virginia where he operates a public warehouse. Petitioner
Gulf Oil Corp. is a gas company organized under the laws of Pennsylvania and qualified to do
business in both Virginia and New York where it has agents to receive processes.

Respondent filed an action in New York against Petitioner for the latter’s negligence in
the delivery of gasoline to the former’s warehouse tanks and pumps that resulted to a fire
destroying the building and all its contents. Gulf Oil invoked the doctrine of forum non-
conveniens and claimed that Virginia is the appropriate venue for the trial because it is where
Gilbert resides, the corporation does business, factual events took place, witness resides and both
state and federal courts are available to Respondent and have jurisdiction over Petitioner. On the
other hand, Gilbert justified his New York suit based on diversity of citizenship and the venue
statutes of the United States authorizing the same. It further contended that the local jury is
unaccustomed to damages amounting to USD 400,000.00 and it prevents local influences and
preconceived notions.

The District Court of New York rendered a decision in favour of Gulf Oil which the
Circuit Court of Appeals later on reversed. Hence, the petition for certiorari.

Issue/s:
Whether the District Court abused its power to dismiss the case pursuant to the doctrine
of forum non conveniens.

Ruling:
No. The principle of forum non conveniens enables a court to resist jurisdiction even
when jurisdiction is authorized by law. The application of the doctrine lies in the discretion of
the court which shall be based on the standpoint of litigants, relative ease of access to sources of
proof, availability of compulsory process for attendance of unwilling witnesses, cost of obtaining
attendance of willing witnesses, possibility of view of the premises, enforceability of a judgment,
and all other practical problems that make trial of a case easy, expeditious, and inexpensive. In
view of public interest, the doctrine aims to prevent clogging court dockets and burdening a
community of jury duty which has no relation to the litigation. There can also be local interest
over controversies decided at home, and some cases are better decided in a forum that is at home
with the state law, avoiding unnecessary problems in conflict of laws.

In the case at bar, there is no interest for any party to have the litigation in New York, and
the facts under consideration even weigh against it. The plaintiff cannot choose an inconvenient
forum to harass the petitioner.