In a recent decision on the availability of the doctrine of forum non conveniens under Oregon law (Espinoza v. EVERGREEN HELICOPTERS, INC., 359 Or. 63), the Oregon Supreme Court cited Professor Petsche's article: A Critique of the Doctrine of Forum Non Conveniens, 24 Fl. J. Int'l L. 545-581 (2012), in which he argues that the doctrine of forum non conveniens is frequently applied in an arbitrary manner and that it is unnecessary insofar as the function assigned to it can be performed more adequately by suitable jurisdictional rules. In its decision, the Supreme Court acknowledged that such criticism "may well have merit" but ultimately held that "we do not find any of those considerations to be so weighty as to cause us to reject the doctrine entirely."