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Keywords

plaintiffdefendantnegligencestatuteappealtrial

tortplaintiffstatuteappealtrial

Related Cases

Pfau v. Trent Aluminum Co., 55 N.J. 511, 263 A.2d 129

Facts

The plaintiff, Steven Pfau, a Connecticut domiciliary, was injured while a passenger in a car driven by Bruce Trent, a New Jersey domiciliary, in Iowa. The accident occurred when Trent failed to negotiate a curve, colliding with another vehicle. Both the plaintiff and defendant were students at Parsons College in Iowa, and the car was registered in New Jersey. The defendants claimed the Iowa guest statute as a defense, which the trial court initially struck down, leading to the appeal.

The facts pertinent to this appeal are undisputed.

Issue

Whether the Iowa guest statute applies to a negligence action brought by a guest passenger against a host-driver when both parties are domiciled in different states.

The sole question presented by this appeal is whether the Iowa guest statute is applicable to this action.

Rule

The court applied the governmental interest analysis approach to determine which state's law should apply, rejecting the traditional Lex loci delicti rule.

In Mellk v. Sarahson, 49 N.J. 226, 229 A.2d 625 (1967) this Court abandoned the old Lex loci delicti rule for determining choice of law in tort cases.

Analysis

The court found that Iowa's interest in applying its guest statute was minimal since the accident involved parties who were not Iowa domiciliaries and the insurance was from New Jersey. The court emphasized that both Connecticut and New Jersey laws required a host to exercise ordinary care for the safety of their guests, indicating a false conflict between the states.

It is clear to us that Iowa has no interest in this suit.

Conclusion

The court reversed the Appellate Division's order and reinstated the trial court's order, allowing the plaintiff to maintain his action for ordinary negligence.

For the reasons expressed the order of the Appellate Division is reversed and the order of the trial court striking the separate defense of the Iowa guest statute is reinstated.

Who won?

The plaintiff, Steven Pfau, prevailed because the court determined that the Iowa guest statute did not apply, allowing him to sue for ordinary negligence under New Jersey law.

The plaintiff, Steven Pfau, prevailed because the court determined that the Iowa guest statute did not apply.

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