Dow Chemical Company v. Castro Alfaro
Supreme Court of Texas
786 S.W.2d 674 (1990)
Domingo Castro Alfaro (plaintiff), a Costa Rican employee of Standard Fruit Company, and other Costa Rican workers sued Dow Chemical (headquartered in Michigan) and Shell Oil (headquartered in Texas) (defendants) in Texas state court, alleging injuries from exposure to the pesticide DBCP on Costa Rican land. The trial court dismissed the case under forum non conveniens, reasoning Costa Rica was the more appropriate forum. The intermediate appellate court reversed, holding the Texas Legislature had abolished the doctrine by statute, and the Texas Supreme Court took the case.
Whether the doctrine of forum non conveniens gives a Texas court discretion to decline jurisdiction over a case when a more convenient forum exists elsewhere.