Victor Amiot v. David Ames

Summary

The Court adopted the significant-relationship approach for tort choice-of-law disputes involving multiple states or countries, replacing automatic application of the law of the place of injury. Because the sparse record did not establish where the conduct causing the injury occurred or which jurisdiction had the most significant relationship, the Court remanded for factual development and a new choice-of-law determination. The Court also held that the judge, rather than the jury, should resolve the factual issues necessary to the choice-of-law determination. Morse, J., concurring in part and dissenting in part, agreed with the choice-of-law approach but would have submitted merits-determinative factual issues to a jury.