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.