Plaintiff sued Defendant for injuries suffered from a car accident in Quebec. Defendant filed a motion to strike, arguing the case was precluded under Quebec law.
In torts cases, the law of the state with the most significant relationship to the litigation will be applied.
Roseanna O’Connor (Plaintiff) sued Brian O’Connor (Defendant) for serious and permanent injuries suffered from a car accident in Quebec. Both parties were residents of Connecticut. Defendant filed a motion to strike, arguing that Quebec law governed the case and Quebec law precluded the plaintiff’s action.
Under Connecticut’s choice of law doctrine, does Quebec law apply to this torts case?
No, Connecticut law applies because it has the most significant relationship to the litigation. The lower court’s decision is reversed and remanded.
The Court first concluded for purposes of reason and justice to not apply lex loci delicti to the facts of this case, relying on the Restatement Second of Conflict of Laws to guide a new approach to issues of choice of law. Applying this new choice of law doctrine, the Court concluded that Connecticut law, not Quebec law, applied to the case. Connecticut had the most significant relationship to the litigation because both parties were residents of the state and could reasonably anticipate being subject to Connecticut’s No-Fault Motor Vehicle Insurance Act. By contrast, the purpose of Quebec’s Automobile Insurance Act is not related to the issues in this litigation.