Tranter v. Z&D Tour, Inc., 2025 Pa. LEXIS 1522 (September 25, 2025) Wecht. J.
Judges: Todd, C.J., Donohue, Dougherty, Wecht, Mundy, Brobson, McCaffery, JJ. Chief Justice Todd and Justices Donohue, Doughtery, Brobson, and McCaffery join the opinion. Justice Mundy files a concurring opinion in which Justice McCaffery joins.
OPINION by JUSTICE WECHT: These consolidated appeals concern the doctrine of forum non conveniens. This legal principle and its associated procedural rule authorize intrastate transfer of a civil litigation from the venue in which the plaintiff chooses to file suit to one more appropriate under the circumstances. The instant cases arose from a multi-vehicle collision that occurred in Westmoreland County, in western Pennsylvania. The plaintiffs elected to bring suit across the state in Philadelphia County, on Pennsylvania’s eastern border. A judge of the Court of Common Pleas of Philadelphia County granted defense petitions to transfer the litigation to Westmoreland County on forum non conveniens grounds, highlighting the number of potential witnesses who would be forced to travel a great distance. The Superior Court reversed, concluding that the defendants failed to provide sufficient detail establishing that the identified individuals were “key witnesses” who would provide “relevant and necessary” testimony that would be “critical to their defenses.” Because the intermediate court’s “key witness” requirement finds no support in this Court’s precedent and imposes an excessively high burden upon the defense, we reverse the Superior Court’s order. The trial court’s transfer to Westmoreland County was wholly proper.
