Schubert v. Target Stores, Inc.
201 S.W.3d 917, 360 Ark. 404, 201 S.W.3d 909 (2005)
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Rule of Law:
In a conflicts-of-law analysis for a tort claim, Arkansas courts will not mechanically apply the law of the state where the injury occurred (lex loci delicti) if Arkansas has significant contacts with the dispute and its own law represents the 'better rule of law,' particularly when the forum's law provides a remedy that the other state's law would bar.
Facts:
- Roger Schubert, an Oklahoma resident, was employed as a truck driver for J.B. Hunt Transport, Inc. (Hunt), an Arkansas corporation.
- Target Stores, Inc. (Target) contracted with Hunt for transportation services, and the contract required Hunt to provide workers' compensation insurance covering Target.
- On February 19, 1999, Target employees at its distribution center in Maumelle, Arkansas, loaded a trailer with 1000-pound bales of cardboard.
- Schubert picked up the sealed trailer in Arkansas and transported it to a facility in Mansfield, Louisiana.
- Upon opening the trailer doors in Louisiana, one of the large cardboard bales fell out and struck Schubert, causing him injuries.
Procedural Posture:
- Schubert filed a workers’ compensation claim against his employer, J.B. Hunt, in Oklahoma and received an award.
- Schubert filed a negligence complaint against Target in the Pulaski County Circuit Court in Arkansas, a court of first instance.
- Target filed a motion for summary judgment, arguing Louisiana law applied and barred Schubert's claim under the 'statutory employer' doctrine.
- The circuit court granted summary judgment in favor of Target, applying Louisiana law.
- Schubert, as appellant, appealed the circuit court's grant of summary judgment to the Supreme Court of Arkansas.
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Issue:
In a personal injury case where the alleged negligence occurred in Arkansas but the resulting injury occurred in Louisiana, does Arkansas's choice-of-law doctrine require applying Louisiana law, which would bar the suit, over Arkansas law, which would permit it?
Opinions:
Majority - Robert L. Brown
No. In a choice-of-law analysis, Arkansas law should be applied instead of the law of the state where the injury occurred when Arkansas has significant contacts with the case and its law is considered the better rule of law. While the traditional rule of lex loci delicti (law of the place of injury) is a starting point, it has been softened by the consideration of five choice-influencing factors established in Wallis v. Mrs. Smith’s Pie Co. Here, the alleged negligence—the loading of the truck—occurred in Arkansas, and the primary employer, Hunt, is an Arkansas corporation, establishing significant contacts. Critically, under the fifth factor, Arkansas law is the 'better rule of law' because it allows an injured party to pursue a negligence claim against a third party like Target. In contrast, Louisiana's 'statutory employer' doctrine would completely bar the claim, denying the plaintiff his day in court, a result this court disfavors.
Analysis:
This case solidifies the evolution of Arkansas's choice-of-law jurisprudence away from a rigid, territorial approach (lex loci delicti) towards a more flexible, policy-based analysis. By heavily weighing the 'advancement of the forum's governmental interests' and the 'better rule of law,' the court signals a preference for applying Arkansas law when it provides a remedy for an injured party, especially when the tortious conduct originated within the state. This decision increases the likelihood that Arkansas courts will apply their own law in multi-state tort cases, making the state a more favorable forum for plaintiffs whose claims might be barred by the laws of the states where their injuries physically occurred.
