Tuner v. Club Med, Inc.

HILL, J.,

The issue before this court is whether Pennsylvania or French law should be applied to the substantive issues in this case involving the drowning of a Pennsylvania resi*497dent at a resort in Martinique, a department of France.

In Griffith v. United Airlines, Inc., Pennsylvania abandoned the traditional practice of mechanically applying the law of “the place of the wrong” in addressing confliet-of-laws issues and sought a more flexible approach. Griffith v. United Airlines, Inc., 416 Pa. 1, 21, 203 A.2d 796 (1964). While the Griffith court was clear in its rejection of the traditional…