Fitts v. Minnesota Min. & Mfg. Co.
581 So. 2d 819, 1991 WL 102125 (1991)
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Rule of Law:
In tort actions, Alabama courts will determine the substantive rights of the parties according to the law of the state where the injury occurred, a principle known as lex loci delicti.
Facts:
- Dr. William Gafford, his wife Susan, and their three children were residents of Tuscaloosa, Alabama.
- In August 1983, the family was returning home from a vacation in Florida.
- Dr. Gafford was piloting a plane designed and manufactured by Gulfstream Aerospace Corporation.
- The plane contained a flight instrument called a 'Stormscope,' designed and manufactured by Minnesota Mining & Manufacturing Company ('3M').
- The plane crashed shortly after takeoff near Ebro, Florida.
- All five members of the Gafford family were killed in the crash.
Procedural Posture:
- Floyd O. Fitts, on behalf of the estates of Susan Gafford and her children, filed a wrongful death and product liability suit against Gulfstream Aerospace Corporation and 3M in the Circuit Court of Jefferson County, Alabama (a state trial court).
- Plaintiffs filed a pre-trial motion asking the trial court to rule that Alabama's substantive law, rather than Florida's, would apply to the case.
- In the alternative, the plaintiffs requested that the trial court certify the choice-of-law issue for an interlocutory appeal to the Supreme Court of Alabama.
- The trial court implicitly ruled that Florida law applied, and Fitts (the appellant) was granted permission to appeal this choice-of-law determination before trial.
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Issue:
Should Alabama abandon its traditional choice-of-law rule of lex loci delicti in favor of the 'most significant relationship' test from the Restatement (Second) of Conflict of Laws for tort cases?
Opinions:
Majority - The Court
No. Alabama's choice-of-law doctrine of lex loci delicti remains the governing principle in tort cases and will not be replaced by the 'most significant relationship' approach. The court recognized its long-standing adherence to the lex loci delicti rule, which provides certainty and predictability. After surveying the various modern approaches adopted by other states, including the Restatement (Second) test, the court found them to be a 'bewildering array' that have not brought uniformity or clarity to the law. Concluding that the newer approaches are 'neither less confusing nor more certain than the traditional approach,' the court declined to abandon a century-old precedent until it becomes clear that a better rule exists.
Concurring - Houston, J.
No. The doctrine of lex loci delicti should be retained because of the critical importance of predictability in the law. This rule has been consistently applied in Alabama for nearly 100 years, making it a predictable standard. A departure from the doctrine of stare decisis is only warranted when a rule of law would not be consented to by the 'conscience and feeling of justice of the majority.' The lex loci delicti rule does not meet this high standard for reversal, and therefore, it should be upheld.
Analysis:
This decision reaffirms Alabama's position as a traditionalist state regarding choice-of-law rules in torts, prioritizing certainty and predictability over the more flexible, policy-based analyses used by a majority of other jurisdictions. By retaining the lex loci delicti rule, the court ensures that the location of the injury is the sole determinant for which state's substantive law applies. This provides a clear, bright-line rule for litigants but can lead to outcomes where the state with the most significant interest in the dispute (e.g., the parties' home state) does not have its laws applied. The case solidifies Alabama's place in the minority of states that reject the modern approach of the Restatement (Second) of Conflict of Laws.
