Aranda v. Philip Morris USA Inc.

Summary

The Court held that the existence of an available alternative forum is a factor in, but not a threshold requirement of, Delaware's forum non conveniens analysis. Because the Superior Court considered Argentina's availability and found overwhelming hardship to the defendants under the applicable factors, the Court affirmed dismissal. The Court also upheld the refusal to impose conditions on dismissal because the plaintiffs raised the requested conditions too late and, in any event, the Superior Court acted within its discretion. Justice Vaughn concurred in the judgment but would generally require an adequate alternative forum as a threshold condition.