This Note considers the doctrine of forum non conveniens in American courts following the Supreme Court’s decision in Piper Aircraft Co. v. Reyno.  The discussion centers on Abdullahi v. Pfizer, Inc., a case brought by Nigerian plaintiffs against Pfizer in the Southern District of New York in 2002.  The case concerned Pfizer’s allegedly tortious actions in undertaking experimental drug testing on Nigerian children without adequate safety precautions, resulting in injury or death to many children.  Despite overwhelming evidence that Nigerian courts would be unwilling to hear the plaintiffs’ claims, the suit was eventually dismissed on grounds of forum non conveniens because “the vexation Pfizer would incur in pursuing discovery in Nigeria while litigating in the U.S. was ‘grossly disproportionate’ to any convenience the plaintiffs might experience by litigating in the U.S.”

This Note argues that such a result is not only inequitable but actually in conflict with the animating purposes of the forum non conveniens doctrine.  After considering the Piper case, this Note explains why the test articulated in Piper is in fact more deferential to a plaintiff’s choice of forum than the Abdullahi opinion suggests and, in any case, should probably not be extended into cases such as Abdulllahi.  In light of cases like Abdullahi, the balancing test of public and private interests that was articulated in Gulf Oil Co. v. Gilbert should be reworked so that courts can give greater consideration to the actual adequacy of the alternative forum to hear a plaintiff’s claims.  A test that focuses on the adequacy of the alternative forum will prevent unjust results and promote greater consistency with the underlying purpose of the forum non conveniens doctrine.