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Phillips v. General Motors Corp.

Montana Supreme Court
995 P.2d 1002 (2000)


Facts

In 1995, Darrell Byrd purchased a used truck that was manufactured in Michigan by General Motors Corp. (GM) (defendant). Byrd bought the truck in North Carolina, where he and his family may have resided at the time. In 1997, Darrell, his wife Angela, and their two sons, Timothy and Samuel, were driving from their home in Montana to visit relatives in North Carolina when they were in an accident in Kansas. The truck caught fire. Darrell, Angela, and Timothy all died; Samuel was injured. Alvin Phillips (plaintiff), acting as Samuel’s guardian and representing the estates of Darrell, Angela, and Timothy, filed a product-liability action against GM in a federal district court in Montana. Phillips resided in North Carolina, as did Samuel after the death of his parents. Montana had no established choice-of-law rule for tort cases. Thus, in considering which state’s law to apply, the federal district court certified three questions to the Montana Supreme Court: (1) Would Montana apply the most-significant-relationship test from the Restatement (Second) of Conflict of Laws (Restatement)? (2) Which state’s law should be applied to the case? (3) Would Montana recognize a public-policy exception so as to require application of Montana law regardless of the court’s choice-of-law analysis?

Rule of Law

Issue

Holding and Reasoning (Regnier, J.)

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