Ayco Farms, Inc. v. Rodriguez Ochoa, No. 15-55611 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit affirmed the dismissal of Ayco Farm's complaint for breach of an exclusivity agreement under the doctrine of forum non conveniens. The panel held that in performing a forum non conveniens analysis, a district court does not abuse its discretion by comparing the proposed foreign forum with the forum that the plaintiff actually chose, rather than with the United States as a whole. In this case, the district court did not err in affording less deference to Ayco Farm's choice to file a lawsuit in California. Furthermore, the district court properly balanced the private and public interest factors and decided that they strongly favor trial in Mexico.
Court Description: Forum Non Conveniens The panel affirmed the district court’s order dismissing Ayco Farms, Inc.’s complaint under the doctrine of forum non conveniens. The panel held that in performing a forum non conveniens analysis, the district court did not abuse its discretion by comparing the proposed foreign forum (Mexico) with the forum that the plaintiff actually chose (California), rather than with the United States as a whole. The panel held that the district court did not err in affording less deference to Ayco’s choice to file a lawsuit in California where Ayco had limited contacts with California. The panel held that the district court properly found that the private interest factors strongly favored trial in Mexico, and the public interest factors supported the foreign forum. The panel concluded that the district court did not err in balancing the private and public interest factors, and in concluding that they strongly favored dismissal.
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