Precision Gear Co. v. Continental Motors, Inc.

“This appeal presents a classic example of the wilderness in which courts sometimes find themselves when searching for solutions to problems arising under the judicial nightmare known as Conflict of Laws.”

Forsyth v. Cessna Aircraft Co., 520 F.2d 608, 609 (9th Cir.1975).

I agree that we must apply the choice-of-law principles of the forum state, in this case Aabama, in order to decide which state’s substantive law will be applied to the claims at issue. Aabama follows the traditional principles of lex loci contractus and lex loci delicti that may direct us to the law of different states…