lex loci delicti rule (Alabama) · Go Syfert
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lex loci delicti rule in Alabama

7 Alabama opinions name it 2 courts 1980–2014 0 in the last five years

The cases below were cited by Alabama courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Fitts v. Minnesota Min. & Mfg. Co.green
ala · 1991 · cited in 2 Alabama opinions naming this issue, 1997–2014
2 sentences

2014Co., 581 So.2d 819, 820 (Ala.1991) (“Under th[e] principle [of lex loci delicti ], an Alabama court will determine the substantive rights of an injured party according to the law of the state where the injury occurred.”).

1997See, e.g., Fitts , 581 So.2d at 823 ; Powell v. Sappington , 495 So.2d 569 (Ala. 1986); and Norris v. Taylor , 460 So.2d 151 (Ala. 1984).

22
Etheredge v. Genie Industries, Inc.green
ala · 1994 · cited in 2 Alabama opinions naming this issue, 1995–1997
2 sentences

1997Although Fitzgerald's argument is based on the legal principle underlying the lex loci delicti rule, which requires a state to apply only the substantive law of the other state, he incorrectly contends that § 25-5-11 (c) is procedural in nature. " 'The distinction between "substance" and "procedure" has medieval origins: a court will apply foreign law only to the extent that it deals with the substance of the case, i.e., affects the outcome of the litigation, but will rely on forum law to deal with the "procedural" aspects of the litigation.' " Etheredge v. Genie Industries, Inc. , 632 So.2d 1

1995When applying the law of another state pursuant to the lex loci delicti principle, this court "enforce[s] only those laws of the other state which are substantive in nature." Id. at 1326 .

12
Management Science America, Inc. v. NCR Corp.green
gand · 1991 · cited in 1 Alabama opinions naming this issue, 2014–2014
1 sentence

2014See Management Science America, Inc. v. NCR Corp., 765 F.Supp. 738, 740 (N.D.Ga.l991)(examining cases from Indiana and Tennessee in determining that ‘[fjederal courts ... consistently have considered [fraud] to have been committed in the state where the economic loss occurred and not where the fraudulent misrepresentations were made.’); Steele v. Ellis, 961 F.Supp. 1458 (D.Kan.1997); Restatement of Conflict of Laws § 377 (1934).

11
Middleton v. Caterpillar Indus., Inc.green
ala · 2007 · cited in 1 Alabama opinions naming this issue, 2011–2011
1 sentence

2011Although lex loci delicti governs substantive law, lex fori— the law of the forum — governs procedural matters.” Middleton v. Caterpillar Indus., Inc., 979 So.2d 53, 57 (Ala.2007) (quoting Fitts v. Minnesota Mining & Mfg.

11
Wardell v. Richmond Screw Anchor Co.green
gactapp · 1974 · cited in 1 Alabama opinions naming this issue, 1992–1992
2 sentences

1992As another court has stated, '[adoption of this exception would allow] a claimant with a choice of jurisdictions in a compensation claim . . . to juggle with the substantive law uniformly applied . . . and thus defeat its application.' Wardell v. Richmond Screw Anchor Co. , 133 Ga. App. 378 , 382 , 210 S.E.2d 854 , 857 (1974).

1992As another court has stated, '[adoption of this exception would allow] a claimant with a choice of jurisdictions in a compensation claim . . . to juggle with the substantive law uniformly applied . . . and thus defeat its application.' Wardell v. Richmond Screw Anchor Co. , 133 Ga. App. 378 , 382 , 210 S.E.2d 854 , 857 (1974).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alabama. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Powell v. Sappington green
ala · 1986
2 sentences

1997The court stated: "We therefore hold that a claimant who is injured in another state cannot evade the application of the lex loci delicti rule merely by filing his [workers'] compensation claim in Alabama." Id.

1992We therefore hold that a claimant who is injured in another state cannot evade the application of the lex loci delicti rule merely by filing his workmen's compensation claim in Alabama." Powell , 495 So.2d at 570 .

21992–1997
Steele v. Ellis green
ksd · 1997
1 sentence

2014See Management Science America, Inc. v. NCR Corp., 765 F.Supp. 738, 740 (N.D.Ga.l991)(examining cases from Indiana and Tennessee in determining that ‘[fjederal courts ... consistently have considered [fraud] to have been committed in the state where the economic loss occurred and not where the fraudulent misrepresentations were made.’); Steele v. Ellis, 961 F.Supp. 1458 (D.Kan.1997); Restatement of Conflict of Laws § 377 (1934).

12014–2014
Norris v. Taylor green
ala · 1984
1 sentence

1997See, e.g., Fitts , 581 So.2d at 823 ; Powell v. Sappington , 495 So.2d 569 (Ala. 1986); and Norris v. Taylor , 460 So.2d 151 (Ala. 1984).

11997–1997
Boudreau v. Baughman green
nc · 1988
2 sentences

1994Boudreau v. Baughman, 322 N.C. at 340-41 , 368 S.E.2d at 857 .

1994Boudreau v. Baughman, 322 N.C. at 340-41 , 368 S.E.2d at 857 .

11994–1994
Larue v. C. G. Kershaw Contracting Co. green
ala · 1912
2 sentences

1992Kershaw Contracting Co. , 177 Ala. 441 , 59 So. 155 (1912), and actions arising under the worker's compensation laws.

1992Kershaw Contracting Co. , 177 Ala. 441 , 59 So. 155 (1912), and actions arising under the worker's compensation laws.

11992–1992
Spencer v. Malone Freight Lines, Inc. green
· 1974
2 sentences

1980Spencer v. Malone Freight Lines, Inc. , 292 Ala. 582 , 298 So.2d 20 (1974); Alabama Great Southern R.R.

1980Spencer v. Malone Freight Lines, Inc. , 292 Ala. 582 , 298 So.2d 20 (1974); Alabama Great Southern R.R.

11980–1980
Gutierrez v. Collins green
tex · 1979
1 sentence

1980For recent nationwide lists of state decisions abandoning or retaining the lex loci delicti rule, see Comment, Abandonment of Lex Loci Delicti in Texas: The Adoption of the Most Significant Relationship Test , 33 Sw.L.J. 1221, note 4 (1980), and Gutierrez v. Collins , 583 S.W.2d 312 , 316 , note 2 (Tex. 1979).

11980–1980

Where else courts name it

FL 19 (1967–2017) PA 19 (1964–2025) MI 17 (1968–2002) MD 15 (1981–2024) WV 14 (1987–2024) IN 12 (1980–2024) NC 12 (1989–2020) GA 11 (1996–2023) CT 11 (1986–2000) IL 10 (1969–2007) NY 10 (1955–1994) NM 7 (1976–2015) AL 7 (1980–2014) NJ 7 (1973–2006) RI 7 (1968–2011) TX 6 (1979–2009) MO 6 (1969–1988) WA 5 (2012–2025) AR 5 (1977–2021) WI 5 (1965–2024) DE 5 (1979–2011) VA 5 (2006–2024) SC 4 (1964–2015) MA 3 (1997–2004) ND 3 (1972–1998) SD 3 (1989–1997) LA 3 (1973–1981) KS 3 (1985–2024) IA 2 (1971–1973) CO 2 (1973–1978) WY 2 (1988–2015) VT 2 (1989–1997) OK 2 (2003–2026) TN 2 (1992–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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