DeLoach v. Alfred
192 Ariz. 28, 271 Ariz. Adv. Rep. 3, 960 P.2d 628 (1998)
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Rule of Law:
Under the Restatement (Second) of Conflict of Laws § 142, the forum state will apply its own statute of limitations permitting a claim unless maintenance of the claim would serve no substantial interest of the forum and the claim would be barred in a state with a more significant relationship to the parties and the occurrence.
Facts:
- Kevin Hamblin, a California resident, was a passenger in a vehicle operated by Kevin DeLoach, an Arizona resident.
- On June 19, 1994, DeLoach's vehicle collided with a car driven by William Moore, a Tennessee resident, in the state of Tennessee.
- The vehicle driven by Moore was owned by Budget Rent-A-Car.
- Hamblin sustained injuries as a result of the collision.
Procedural Posture:
- On June 19, 1996, Kevin Hamblin (Plaintiff) filed a tort action in an Arizona trial court against Kevin DeLoach (Petitioner).
- DeLoach filed a motion for summary judgment, arguing that Tennessee's one-year statute of limitations barred the claim.
- The trial court judge denied DeLoach's motion, concluding that Arizona's two-year statute of limitations was applicable.
- DeLoach sought special action relief from the Arizona Court of Appeals.
- The Court of Appeals accepted jurisdiction, reversed the trial court, and held that Tennessee's one-year statute of limitations applied.
- Hamblin petitioned the Supreme Court of Arizona for review, which was granted.
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Issue:
Does Arizona's two-year statute of limitations apply to a personal injury claim filed in Arizona by a California resident against an Arizona resident, when the underlying accident occurred in Tennessee, which has a one-year statute of limitations?
Opinions:
Majority - Feldman, Justice
Yes. Arizona's two-year statute of limitations applies because Arizona has a substantial interest in providing a forum for redress and deterring the negligent conduct of its own residents. The court adopted the interest analysis approach of the revised Restatement (Second) of Conflict of Laws § 142, which establishes a general rule that the forum's statute of limitations applies. An exception exists if (a) maintaining the claim serves no substantial interest of the forum, and (b) the claim is barred in a state with a more significant relationship. The court found that Arizona has a substantial interest in requiring its citizens, like DeLoach, to answer for the harm they cause and in deterring wrongful conduct, even when it occurs outside the state. In contrast, Tennessee's interest is diminished because the injured party is a non-resident, and its policy of barring stale claims against its own residents is not frustrated, as the Tennessee defendants are not subject to personal jurisdiction in Arizona. Because Arizona has a substantial interest, the exception to the general rule does not apply.
Analysis:
This decision officially moves Arizona away from the traditional, rigid 'lex fori' approach for statutes of limitations and adopts the modern interest-analysis framework of Restatement § 142. It clarifies that this framework is not a pure balancing test but begins with a strong presumption in favor of applying the forum's law. The ruling establishes a significant precedent that a state's interest in regulating its own domiciliaries and providing a forum for claims against them is a 'substantial interest' that will typically defeat a choice-of-law challenge based on the shorter statute of limitations of the state where the tort occurred. This strengthens the position of plaintiffs suing Arizona residents in Arizona courts for out-of-state incidents.
