Pfau v. Trent Aluminum Co.

Brief Fact Summary

Trent Aluminum (Defendant), sued for personal injury, argued that a foreign state’s choice-of-law rule should be applied if its substantive law were to be applied.

Synopsis of Rule of Law

The substantive law of a state may be applied without also applying its choice-of-law rules.

Facts

Pfau (Plaintiff) and Trent (Defendant) were schoolmates at college in Iowa.  Defendant was a citizen of New Jersey and Plaintiff a citizen of Connecticut.  While driving a vehicle belonging to his father’s company, Trent Aluminum Co. (Defendant), Trent (Defendant) was involved in an automobile accident in Iowa.  Plaintiff was a passenger in the vehicle.  Trent Aluminum (Defendant) argued that Iowa’s guest statute applied, and raised this defense.  Plaintiff successfully moved to strike the defense with the court ruling Connecticut law to be applicable, which contained no guest statute.  The court of appeals reversed holding Connecticut’s choice-of-law rule also to apply.  Since Connecticut applied the lex loci rule, the court held Iowa law applicable.

Issue

May the substantive law of a state be applied without also applying its choice-of-law rules?

Held

(Proctor, J.)  Yes.  The substantive law of a state may be applied without also applying its choice-of-law rules.  Choice-of-law analysis is based on governmental interests, and a nonforum state’s choice-of-law rule does not relate to its substantive interests in a litigation.  This is particularly true when a state adheres to the lex loci rule, which has nothing do with the interests of government.  Consequently, applying Connecticut’s choice-of-law rule would not promote any of its governmental interests in this litigation and should not be applied.  [The court went on to hold that since Connecticut and New Jersey had identical law on the guest statute issue, there was no conflict to resolve.]  Reversed and the order of the trial court reinstated.

Discussion

Some commentators have not taken the position apparently held here that choice-of-law rules are not relevant in a governmental interest analysis.  Some have held, for example, that choice-of-law rules can illustrate precisely what a state’s governmental interests might be, as such interests are likely to be incorporated into choice-of-law rules.  This debate has been largely theoretical; practically speaking, a forum state’s choice-of-law rules are nearly always used.