Thomas Spinozzi (plaintiff), a resident of Illinois, stayed in Acapulco, Mexico at a hotel owned by ITT Sheraton Corporation (defendant), a Mexican corporation. One night when the lights were out, Spinozzi fell into a maintenance pit at the hotel and suffered serious injuries. Although Sheraton was negligent, Spinozzi was also negligent in not staying on marked pathways at the hotel. Spinozzi sued Sheraton in federal district court in Illinois. Mexican law followed the doctrine of contributory negligence, under which a plaintiff’s negligence was a complete bar to recovery. Illinois had abandoned contributory negligence in favor of the doctrine of comparative negligence, under which a plaintiff could be negligent and still recover. Sheraton filed a motion for summary judgment on the ground that, under Mexican law, Spinozzi’s claim was barred by his contributory negligence. The district court, applying Mexican law because Mexico had the most significant relationship to the alleged tort, granted Sheraton’s motion for summary judgment, finding that Spinozzi’s claim was barred due to his contributory negligence. Spinozzi appealed, arguing that because contributory negligence was contrary to Illinois public policy, the court should not apply Mexican law.