Edwards v. Erie Coach Lines Co.
New York Court of Appeals
17 N.Y.3d 306, 952 N.E.2d 1033, 929 N.Y.S.2d 41 (2011)
A bus crashed into a truck near Geneseo, New York. The crash killed three bus passengers and the truck driver, and seriously injured several other bus passengers. The bus driver, his company, and the company that leased the bus (bus defendants) were domiciled in Ontario for choice-of-law purposes. The truck driver, his company, and the company that hired the truck (truck defendants) were domiciled in Pennsylvania. The injured bus passengers and families of the deceased bus passengers (plaintiffs), who were domiciled in Ontario, filed multiple lawsuits in the New York Supreme Court. The plaintiffs argued that the court should analyze the bus defendants and the truck defendants jointly for purposes of choice of law. Ontario law would have capped damages in the suits, whereas New York law would have no cap. The plaintiffs sought application of New York law. The New York Supreme Court applied a joint analysis for both sets of defendants and found that Ontario law applied to the suits. The Appellate Division conducted separate analyses for the bus and truck defendants and found that Ontario law applied to each. The plaintiffs appealed.
Rule of Law
Holding and Reasoning (Read, J.)
Dissent (Ciparick, J.)
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