Estate of Figueroa v. Williams

2010 WL 5387599 (2010)

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Estate of Figueroa v. Williams

United States District Court for the Southern District of Texas
2010 WL 5387599 (2010)

Facts

Tyrone Williams (defendant) illegally smuggled Mexican and Honduran citizens into the United States in his tractor-trailer. Great Dane Trailer (Great Dane) (defendant) was a Delaware limited partnership that owned the trailer, and Salem Trucking, Inc. (Salem) (defendant) was a New York corporation that owned the tractor. Williams abandoned the trailer at a Texas gas station, resulting in 19 deaths. The families of the 19 decedents (collectively, families) (collectively, plaintiffs) sued Williams, Great Dane, and Salem in federal court in Texas for, among other things, wrongful death. The families all lived in Mexico or Honduras and had no other connections to Texas. Great Dane and Salem asked the court to apply the substantive law of Mexico and Honduras instead of Texas’s substantive law because Mexico and Honduras assertedly had the most significant relationships with the parties and the relevant occurrence. The families responded that Texas had the most significant relevant relationships. Mexican and Honduran substantive law differed from Texas law in that (1) Mexican and Honduran law did not recognize survival claims, which Texas law recognized; (2) Mexican and Honduran law computed compensatory damages in more formulaic and less plaintiff-friendly ways than Texas law; and (3) Mexican and Honduran law did not recognize punitive damages, which Texas law recognized.

Rule of Law

Issue

Holding and Reasoning (Rainey, J.)

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