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Under Illinois choice-of-law rules, the law of the place of injury controls unless another state has a more significant relationship with the occurrence and with the parties with respect to the particular issue. That is the starting point for any choice-of-law analysis in personal injury claims.
The family resided in Michigan. The father obtained a riding lawn tractor from the retailer in Michigan. The retailer was a New York corporation domiciled in Illinois and made certain decisions regarding the design of the riding lawn tractor, product testing, distribution of that product, and investigations involving injuries caused by the product in Illinois. The father was mowing his lawn in Michigan using the riding lawn tractor. He did not see his minor son, who was less than four-years-old, walk up behind the riding lawn tractor. The father then backed up and ran over the minor son with the riding lawn tractor. The family sued the retailer in Illinois, alleged strict products liability and negligence claims, and moved to apply Illinois law to the liability and damages issues. The trial court ruled that Illinois law applied to those substantive issues and the appellate court agreed.
Did the appellate court err in affirming the trial court’s ruling that Illinois law applied in this case?
The state supreme court found that Illinois' relationship to the case was not so pivotal as to overcome the presumption that Michigan, as the state where the injury occurred and the family resided, was the state with the most significant relationship to the case.