Townsend v. Sears, Roebuck and Co.
879 N.E.2d 893, 316 Ill. Dec. 505, 227 Ill. 2d 147 (2007)
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Rule of Law:
In a personal injury action, there is a strong presumption that the law of the state where the injury occurred will govern the case, unless another state has a more significant relationship to the occurrence and the parties with respect to the particular issue.
Facts:
- Michelle, James, and Jacob Townsend were residents of Alma, Michigan.
- Sears, Roebuck and Company (Sears) is a New York corporation with its principal place of business and corporate headquarters in Cook County, Illinois.
- In the spring of 2000, James Townsend purchased a Sears Craftsman riding lawn tractor from a Sears store in Michigan.
- The lawn tractor was manufactured in South Carolina.
- In early 2001, James Townsend received an identical replacement lawn tractor under warranty.
- On May 11, 2001, while James was mowing the lawn at his home in Michigan, the tractor backed over his son, Jacob.
- Jacob Townsend suffered severe injuries, including the amputation of his right foot.
- The plaintiffs alleged the tractor was defectively designed in Illinois because it lacked a 'no-mow-in-reverse' safety feature.
Procedural Posture:
- Michelle Townsend, on behalf of her son Jacob, sued Sears, Roebuck and Company in the circuit court of Cook County, Illinois (a trial court), alleging strict product liability and negligence.
- The plaintiffs filed a motion asking the circuit court to apply Illinois law to the issues of liability and damages.
- The circuit court granted the plaintiffs' motion, ruling that Illinois law would govern the substantive issues.
- The circuit court then certified the choice-of-law question for an interlocutory appeal.
- Sears, as appellant, appealed to the Illinois Appellate Court, an intermediate appellate court, with the Townsends as appellees.
- The appellate court affirmed the circuit court's decision, also holding that Illinois law applied.
- The Supreme Court of Illinois, the state's highest court, granted Sears' petition for leave to appeal.
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Issue:
Does Illinois law, where the defendant corporation is headquartered and allegedly made tortious design decisions, apply to a personal injury action when the plaintiffs are residents of Michigan and the injury occurred in Michigan?
Opinions:
Majority - Justice Freeman
No. In a personal injury case, Illinois choice-of-law rules create a strong presumption that the law of the state where the injury occurred governs, unless another state is shown to have a more significant relationship. The court reasoned that under the Restatement (Second) of Conflict of Laws §146, the law of the place of injury is presumptively controlling. To overcome this presumption, a court must analyze the contacts listed in §145(2) (place of injury, place of conduct, domicile of parties, center of relationship) and the policy principles in §6. Here, the injury occurred in Michigan to Michigan residents, the product was purchased in Michigan, and the relationship was centered there. While Sears' alleged tortious conduct (design decisions) occurred in Illinois, this contact was not sufficient to overcome the strong presumption favoring Michigan law. The court held that Michigan's interest in providing remedies for its injured residents was as significant as Illinois's interest in regulating its corporate citizens, and thus the presumption was not rebutted.
Analysis:
This decision solidifies Illinois's choice-of-law methodology in tort cases, emphasizing the importance of the presumptive rules found within the Restatement (Second) of Conflict of Laws. By prioritizing the rule in §146 (law of the place of injury), the court created a high bar for displacing it with the law of another state. This holding discourages forum shopping by preventing plaintiffs from suing a defendant in its corporate headquarters' state merely to access more favorable substantive law. The case establishes a more predictable, structured approach, moving away from a free-form 'interest analysis' and towards a clear, two-step process that gives significant weight to the location of the injury.
