A car driven by William Jackson (defendant) crashed into a wall, injuring passenger Georgia Babcock (plaintiff). Babcock and Jackson were residents of New York, but the accident occurred in Ontario, Canada, during a weekend visit. When the accident occurred, Ontario statutory law stated the driver of a noncommercial vehicle was not liable for the injury or death of a passenger in the vehicle. New York had no such law. Babcock sued Jackson in New York state court. The trial court, applying Ontario law, dismissed the complaint. The appellate division affirmed.