LaForge v. Normandin

Although plaintiff and the moving defendants are all residents of Quebec, four codefendants are domiciliaries of New York, and one of the codefendants is a municipal corporation. We thus are presented with a matter involving domiciliaries of different jurisdictions with conflicting loss-distribution rules. In such cases, "the law of the place of the tort will normally apply, unless displacing it ' "will advance” the relevant substantive law purposes without impairing the smooth working of the multi-state system or producing great uncertainty for litigants’ ” (Schultz v Boy Scouts, 65 NY2d…