Precision Gear Co. v. Continental Motors, Inc.

When presented with a conflict-of-laws issue, Alabama courts apply the principles of lex loci delicti and lex loci contractus.

“Alabama law follows the traditional conflict-of-law principles of lex loci con-tractus and lex loci delicti. Under the principles of lex loci contractus, a contract is governed by the law of the jurisdiction within which the contract is made. Under the 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.”

Lifestar Response of Alabama, Inc. v. Admiral Ins.…