Supreme Court Report

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Thomas Levien, et al. v. HIBU PLC, et al.

Paid petition · United States Court of Appeals for the Third Circuit, No. 20-2731 · judgment December 2, 2021


Certiorari denied · June 13, 2022
Pre-decision estimate: 3% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

The Questions Presented all apply to the standards for resolving a motion for forum non conveniens dismissal.

  1. As a matter of law, is a proposed alternative forum adequate and/or available if its statute of limitations applicable to the plaintiffs’ claims has expired?

  2. May a district court disregard the burden of proof in a forum non conveniens analysis by dismissing on a ground never raised or argued by the defendants, and doing so without any supporting evidence of record?

  3. In an action involving both American and foreign plaintiffs, is a court analyzing the issue required to give great deference to the plaintiffs’ choice of an American federal forum?

  4. If a district court determines a forum non conveniens dismissal is appropriate, in an action where jurisdiction is lacking in the new forum, or the applicable statute of limitations has expired there, must the court condition the dismissal on the defendants’ agreement not to assert those defenses?

Counsel of record

For petitioner
Clifford E. Haines
Haines & Associates

For respondent
Scott Sonny Balber
Herbert Smith Freehills New York LLP

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Jun 13 2022
    Petition DENIED.
  2. May 24 2022
    DISTRIBUTED for Conference of 6/9/2022.
  3. May 20 2022
    Waiver of right of respondent HIBU PLC, et al. to respond filed.
  4. May 11 2022
    Petition for a writ of certiorari filed. (Response due June 17, 2022)