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Keywords

liabilitystatuteappealproduct liability

liabilitystatutesummary judgment

Related Cases

Nesladek v. Ford Motor Co., 46 F.3d 734

Facts

On April 18, 1990, Jeremy Nesladek was severely injured when a Ford pickup truck rolled over him. He died from his injuries two years later. After his death, the Nesladek family moved to Minnesota, where Jill Nesladek filed a wrongful death suit against Ford in federal court. Ford argued that the claim was barred by Nebraska's ten-year statute of repose for product liability actions, which the District Court agreed with, leading to the dismissal of the case.

After Jeremy's death, the Nesladeks moved to Minnesota. Jill Nesladek brought this wrongful death suit in Minnesota state court. Ford removed the case to federal court and moved for summary judgment, arguing that Nesladek's claim was barred by Nebraska's ten-year statute of repose applicable to products liability actions.

Issue

Whether the District Court correctly applied Nebraska's statute of repose to bar the wrongful death claim under Minnesota's choice of law rules.

All agree that this is a conflict of laws case.

Rule

Under Minnesota law, the first issue in a conflict of laws case is whether the law at issue is substantive or procedural. If substantive, the court must apply the choice of law analysis to determine which state's law governs the case.

Under Minnesota law, the first issue that must be resolved before we may choose between Nebraska and Minnesota law is whether the law at issue is substantive or procedural.

Analysis

The court determined that both Nebraska's statute of repose and Minnesota's useful life statute were substantive laws. It applied Minnesota's choice-of-law rules and concluded that Nebraska law governed the case because the majority of events occurred in Nebraska, and the Nesladeks had engaged in forum shopping by moving to Minnesota to file the suit.

Having determined that the Minnesota courts would characterize the statutes in question as substantive does not end our inquiry; it means only that we do not automatically apply Minnesota law.

Conclusion

The Court of Appeals affirmed the District Court's decision, holding that the Nebraska statute of repose applied and barred the wrongful death claim.

Accordingly, the judgment of the District Court is affirmed.

Who won?

Ford Motor Company prevailed in the case because the court found that the claim was barred by Nebraska's statute of repose, which precluded any cause of action from accruing.

We conclude that the maintenance-of-interstate-order factor favors the choice of Nebraska law.

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