Fitts v. Minnesota Mining & Manufacturing Co.

Dr. William Gafford, his wife Susan, and their three children were killed when a plane being piloted by Dr. Gafford crashed in Florida. All five family members were residents of Alabama and were on their way home from a Florida vacation. Two separate wrongful suits were filed in state court in Alabama. The first suit was filed by William F. Gafford, Sr. (Gafford), as administrator of the estate of Dr. William Gafford. The second suit was filed by Floyd O. Fitts (Fitts) (plaintiff), the father of Susan Fitts Gafford, on behalf of her and the children. Both suits named as defendants the designer and manufacturer of the plane—Gulfstream Aerospace Corporation (Gulfstream) (defendant)—and the designer and manufacturer of the Stormscope flight instrument—Minnesota Mining & Manufacturing Company (3M) (defendant). Gulfstream and 3M contended that their products were not defective and that Dr. Gafford was contributorily negligent. Before trial, Gafford and Fitts filed a motion and requested the trial court to rule that Alabama substantive law (as opposed to Florida substantive law) applied. Under Florida wrongful-death law, the only compensable damages for the death of Susan and her children were funeral expenses. The trial court determined that under Alabama’s traditional choice-of-law rule, lex loci delicti, the law of the place of the injury—Florida—applied. Fitts appealed and argued that the lex loci delicti rule was outmoded and unfair and urged the court to adopt the significant-relationship test in the Restatement (Second) of Conflict of Laws.