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Pfau v. Trent Aluminum Co.

Supreme Court of New Jersey
263 A.2d 129 (1970)


Facts

Steven Pfau (plaintiff) and Bruce Trent (defendant) attended the same college in Iowa. Pfau was a domiciliary of Connecticut, Trent of New Jersey. While on campus, Trent operated a vehicle owned by his father’s company, Trent Aluminum Co. (defendant), a New Jersey corporation. Pfau was a passenger in Trent’s vehicle when Trent got into an accident in Iowa. Pfau was injured. He sued Trent and Trent Aluminum in a New Jersey court for negligence. Defendants asserted, as a defense, application of Iowa’s guest statute, which precluded a guest-passenger from suing the host-driver for ordinary negligence. Neither Connecticut nor New Jersey law contained a guest statute. In favor of Pfau, the trial court struck the guest statute defense. An appellate court reversed. Pfau appealed to the Supreme Court of New Jersey. Defendants argued that if Connecticut law rather than Iowa law should apply, the court should then also apply Connecticut’s conflict-of-law rules, which designated the lex loci delicti—Iowa in this case—as the governing law for torts.

Rule of Law

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Issue

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Holding and Reasoning (Proctor, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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