Alexander v. General Motors Corp.
267 Ga. 339, 478 S.E.2d 123, 96 Fulton County D. Rep. 4131 (1996)
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Rule of Law:
Under the public policy exception to the rule of lex loci delicti, Georgia's strict products liability law will apply to a tort action filed in Georgia, even if the injury occurred in a state that does not recognize strict liability, when the product was purchased in Georgia and the foreign state's law is antithetical to Georgia's strong public policy of shifting the burden of loss from consumers to manufacturers.
Facts:
- Alexander purchased a new General Motors vehicle in the state of Georgia.
- While driving the vehicle in Virginia, Alexander was involved in a collision.
- During the collision, the driver's seat of Alexander's vehicle failed.
- As a result of the seat failure, Alexander was ejected from the vehicle and sustained injuries.
Procedural Posture:
- Alexander sued General Motors in a Georgia trial court under a theory of strict liability.
- The trial court granted partial summary judgment to General Motors, ruling that Virginia's substantive law applied.
- The trial court dismissed Alexander's strict liability claims but allowed him to amend the complaint to state a negligence claim under Virginia law.
- Alexander (appellant) appealed to the Georgia Court of Appeals.
- The Court of Appeals affirmed the trial court's judgment, holding the public policy exception did not apply.
- The Supreme Court of Georgia granted Alexander's (appellant's) petition for a writ of certiorari to review the Court of Appeals' decision.
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Issue:
Does Virginia's law, which does not recognize a cause of action for strict products liability, violate the public policy of Georgia as embodied in its strict liability statute (OCGA § 51-1-11), thereby triggering the public policy exception to the rule of lex loci delicti?
Opinions:
Majority - Benham, Chief Justice
Yes, Virginia's law violates Georgia's public policy. The application of the rule of lex loci delicti would contravene the public policy embodied in Georgia's strict liability statute. Georgia's policy is to shift the burden of loss caused by defective products to manufacturers, which is effectuated through strict liability, a doctrine that eliminates the need to prove negligence. Virginia law, which relies on negligence and warranty claims with higher burdens of proof for the plaintiff, is not merely a 'somewhat different method' but is 'radically dissimilar' to Georgia's law. Applying Virginia law would place the injured party in the exact position from which Georgia's statute was intended to provide protection, making it contrary to the public policy of the state.
Analysis:
This decision carves out a significant public policy exception to the traditional conflict of laws rule of lex loci delicti in Georgia products liability cases. It establishes that Georgia's interest in protecting its consumers who purchase goods within its borders can override the principle of applying the law of the place of injury. The case emphasizes that the legal 'method' of recovery (strict liability vs. negligence) is a core component of public policy, not just a procedural difference. This precedent strengthens the position of plaintiffs who purchase products in Georgia and are injured elsewhere, making it more likely that Georgia's plaintiff-friendly strict liability law will govern their claims.
