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Bryntesen v. Camp Automotive, Inc.

United States District Court, D. Idaho

January 20, 2015

CASEY BRYNTESEN, et. al., Plaintiffs,
v.
CAMP AUTOMOTIVE, INC., et. al., Defendants.

MEMORANDUM DECISION AND ORDER

B. LYNN WINMILL, Chief District Judge.

INTRODUCTION

The Court has before it Defendants' Motion Regarding Choice of Law Governing Punitive Damages (Dkt. 56), Defendants' Motion for Sanctions (Dkt. 63), Defendants' Motion to Exclude Plaintiffs' Expert Witness James Bower (dkt. 70), and Defendants' Motion to Exclude Plaintiffs' Rebuttal Experts and Late-Disclosed Experts (Dkt. 91).

ANALYSIS

1. Choice of Law

As both parties recognize, federal courts sitting in diversity apply the choice-of-law provisions of the forum state. Klaxon v. Stentor Elec. Mfg. Co., 313 U.S. 487, 497, (1941). Idaho applies the "most significant relationship" test set out in the Restatement (Second) of Conflict of Laws to determine which state's laws govern tort cases. Section 145 of the Restatement requires courts to consider: (a) the place where the injury occurred, (b) the place where the conduct causing the injury occurred, (c) the domicile, residence, nationality, place of incorporation and place of business of the parties, and (d) the place where the relationship, if any, between the parties is centered. Grover v. Isom, 53 P.3d 821, 824 (Idaho 2002). "Of these contacts, the most important in guiding [the Idaho Supreme Court's] past decisions in tort cases has been the place where the injury occurred.'" Id. (quoting Seubert Excavators, Inc. v. Anderson Logging Co., 889 P.2d 82, 85 (Idaho 1995)).[1]

Once the Court analyzes the § 145 factors, "they are evaluated in light of the following policy concerns [set out in § 6 of the Restatement]": (a) the needs of the interstate and international systems, (b) the relevant policies of the forum, (c) the relevant policies of other interested states and the relative interests of those states in the determination of the particular issue, (d) the protection of justified expectations, (e) the basic policies underlying the particular field of law, (f) certainty, predictability and uniformity of result, and (g) the ease in the determination and application of the law to be applied. Grover, 889 P.2d at 85. These considerations are not designed to be applied in a mechanical way. Rather, the conflict must be rationally evaluated in light of the policies underlying the conflicting rules of law. See Johnson v. Pischke, 700 P.2d 19, 22 (Idaho 1985).

A. Place Where the Injury Occurred

Idaho is the place where the injury occurred in this case. Defendants disagree, noting that Washington is where the borrowed vehicle agreement was signed, that Washington is where the Bryntesens took possession of the loaner vehicle, and that Washington is where the Defendants were when they reported the vehicle stolen. Defendants are correct that all these events occurred in Washington. The question, though, is where did the injury occur? The answer is Idaho. That is where the Bryntesens were pulled over, detained, and questioned by the police.

The Court is also not persuaded by Defendants' suggestion that it was mere happenstance that the Bryntesens were in Idaho when they were pulled over by the police. The Bryntesens are, and were at the time of the incident, residents of Idaho. Thus, they were not unexpectedly in Idaho or in Idaho by chance. Accordingly, the Court finds that the injury occurred in Idaho, and this factor weighs heavily in favor of applying Idaho law.

B. Place Where the Conduct Causing the Injury Occurred

The conduct which caused the injury was the improper reporting of the vehicle as stolen. The place where that occurred could be considered a bit nuanced because a stolen vehicle is typically placed on a national database - suggesting the cause of the injury was nationwide. However, the call to the police reporting the vehicle stolen was made in Washington, and that was the actual cause of the injury. Accordingly, this factor weighs in favor of applying Washington law.

C. The Domocile, Residence, Nationality, Place of Incorporation and Place of Business of the Parties

The Bryntesens live in Idaho, and Defendants live primarily in Washington, with parent companies in Oregon and ...


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