La Fontaine v. Signature Research, Inc., 305 Ga. 107

Plaintiffs Francis La Fontaine and Roberto Melendez, Michigan residents, were injured/affected by a zip-line collapse in the Dominican Republic and sued Signature Research, Inc., a Georgia corporation that inspected/certified the course, in Georgia state court.
Signature moved to dismiss on forum non conveniens grounds, offered to submit to Dominican jurisdiction, and agreed to extend applicable limitations period there.
The trial court granted dismissal under OCGA § 9-10-31.1, concluding private and public factors favored adjudication in the Dominican Republic.
The Georgia Court of Appeals affirmed the dismissal relying on Hewett v. Raytheon Aircraft Co.
The Georgia Supreme Court granted certiorari to decide whether OCGA § 9-10-31.1 permits dismissal in favor of a foreign country forum and took the case up as one of statutory construction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OCGA § 9-10-31.1 authorizes dismissal to a foreign country	Statute does not allow dismissal to a foreign forum; applies only to other U.S. states	Statute permits dismissal to any forum "outside this state," including foreign countries	OCGA § 9-10-31.1 does not authorize dismissal in favor of a foreign country; reversal of dismissal
Whether subsection (b)’s waiver language limits § 9-10-31.1 to sister states	The waiver phrasing ("all other states of the United States") shows the statute targets transfers to other U.S. states	Opposes narrow reading; argues statute’s "outside this state" is broad enough to include foreign fora	Court reads subsection (b) to confine § 9-10-31.1 to other U.S. states; foreign dismissal would render (b) illogical
Whether Hewett v. Raytheon remains controlling	Hewett permitted dismissal to a foreign forum; plaintiffs say it should be overruled	Defendants rely on Hewett and Court of Appeals decision	Court overrules Hewett to the extent it allowed dismissals in favor of foreign fora
Whether other transfer or constitutional grounds were decided	Plaintiffs raised constitutional access and Sigala arguments	Defendant relied on statutory forum non conveniens dismissal only	Court does not decide other transfer doctrines or constitutional issues; left for trial court if raised later

Fulton County Bd. of Ed. v. Thomas, 299 Ga. 59 (2016) (statutory construction reviewed de novo)
Lyman v. Cellchem Intl., Inc., 300 Ga. 475 (2017) (statutory interpretation rules and reading statutes as a whole)
Wegman v. Wegman, 338 Ga. App. 648 (2016) (statutes in derogation of common law must be strictly construed)
Couch v. Red Roof Inns, 291 Ga. 359 (2012) (same canon regarding limiting statutory scope)
Hewett v. Raytheon Aircraft Co., 273 Ga. App. 242 (2005) (Court of Appeals decision permitting foreign-forum dismissal; overruled here)
AT&T Corp. v. Sigala, 274 Ga. 137 (2001) (discusses forum non conveniens and limits on dismissals when constitutional or statutory rights to Georgia courts exist)
Holtsclaw v. Holtsclaw, 269 Ga. 163 (1998) (forum non conveniens controlled by statute in Georgia)