On April 24, 2020, the First Circuit affirmed the District of
Massachusetts' dismissal of a case against General Electric on
forum non conveniens grounds.
In 2011, an earthquake-induced tsunami struck the Fukushima
Daiichi Nuclear Power Plant in Japan. Individuals and businesses
who suffered property damage and/or economic harm from the disaster
filed a class action lawsuit against General Electric, which
designed the power plant's nuclear reactors and safety
mechanisms, in the District Court for the District of
Massachusetts. The district court held Japan provided an adequate
alternative forum and dismissal was in both the private and public
interest.
Plaintiffs had contended venue was proper in the District of
Massachusetts because General Electric's corporate headquarters
and principal place of business are in Boston, Massachusetts.
Plaintiffs alleged the district court had subject matter
jurisdiction because the Convention on Supplementary Compensation
for