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Courts and commentators, in dealing in the past three decades with the increasingly topical doctrine of forum non conveniens in the Federal courts, have sought support for their advocacy of its application in actions at law from what they considered to be its respectable and established status in admiralty. It has also been possible to draw the inference from one or two cases in which the Supreme Court dealt with the doctrine in admiralty that it thought its general statements to have application on the law side as well. In the recent, much noted, twin cases of Gulf Oil Corp. v. Gilbert and Koster v. Lumbermen's Mutual Co., the Court gave definitive judicial sanction to the application of forum non conveniensin actions brought at law or in equity in the Federal courts. Mr. Justice Jackson, speaking in both cases for a 5-4 majority, laid considerable stress on the argument that no unprecedented innovation in Federal practice was being introduced and cited admiralty cases for support. Mr. Justice Black, in a careful dissent, met this point by maintaining that the existence of the doctrine in admiralty was based on the courts' special powers and functions in the exercise of that branch of their jurisdiction, and therefore had no relevance on the law side.
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