South-Western Legal Studies in Business

Substantial Interest Test May Determine Outcome of Choice of Law Question
Description Appeals court held that Virginia law would govern a negligent injury death suit involving a Washington, D.C. resident and a California company, for an injury and death that occurred in Virginia. Under the substantial interest test, Virginia had the most interests, so the federal court in D.C. would apply that law to resolve the matter.
Topic Court Procedure
Key Words Choice of Law; Substantial Interest; Negligence
C A S E   S U M M A R Y
Facts Jaffe, a resident of Washington, D.C., volunteered to participate in AIDSRide, a multiple-day, non-competitive bicycle ride that raises funds for AIDS charities. She signed a liability waiver form in D.C. that held the organizers harmless in the event of her injury or death. The ride was organized by Pallotta, a California corporation that specializes in such events. Jaffe began the ride in North Carolina. Later in the day, while bicycling in Virginia, she felt poorly and went to a medical aid station for the riders. She was given intravenous fluids, but her conditioned worsened. An ambulance was called, but she soon died. Jaffe's mother sued, claiming negligence by the event organizers. The medical station was run by untrained volunteers who over-hydrated her, causing death by global brain hypoxia, which may not have happened had there been trained medical assistance. The federal district court in D.C. granted summary judgment to defendant because of the liability waiver. Jaffe's mother appealed.

Reversed and remanded. Under D.C. choice of law rules, Virginia law, rather than D.C. law, governs the issue of the effect of the waiver signed by Jaffe. D.C. applies the substantial interest test for determining choice of law in tort cases: 1) where the injury occurred; 2) where the conduct that caused the injury occurred; 3) the residency of the parties; and 4) the place where the relationship is centered. Virginia has a more substantial interest in this matter than does D.C., so Virginia law will govern the case.

Citation Jaffe v. Pallotta Teamworks, 374 F.3d 1223 (D.C. Ct. App., 2004)

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