(dissenting). I would affirm the order of the trial court. Therefore, I respectfully dissent. The trial court did not err, in my judgment, in holding that Alabama law should be applied in this case because plaintiff’s decedent was an Alabama resident, the accident that killed plaintiff’s decedent occurred in Alabama, and Alabama’s interest in the application *179of its own law is substantial and outweighs the interests of Michigan in the application of its law.
I concur with the majority in its description of Michigan choice-of-law rules. I also concur in its holding that plaintiff is properly characterized as a resident of Alabama and, therefore, that a balancing of interests between Michigan and Alabama is required. However, I differ in terms of the substantive balancing itself.
Each state has an interest in the application of its laws. With respect to Alabama, decedent was a resident of Alabama for sixty-eight years and the accident in which she was killed occurred on an Alabama road while the occupants were en route to an Alabama destination. “[t]he injury state always has an interest in conduct within its borders whether or not citizens are involved.” Olmstead v Anderson, 428 Mich 1, 28; 400 NW2d 292 (1987). Where, as here, citizens are involved and the death of one of them has occurred, such an interest becomes even more substantial. With respect to Michigan, there is an interest in applying the state’s owners’ liability statute, even to accidents that occur outside the state, because hmiting the enforcement of the statute to in-state accidents would undeniably limit the effectiveness of the statute. Such a limitation would dilute to some extent the effect of the statute in encouraging vehicle owners to entrust their vehicles only to safe drivers. Sexton v Ryder Truck Rental, Inc, 413 Mich 406, 437-438; 320 NW2d 843 (1982).
Therefore, I would conclude that both Alabama and Michigan have an interest in the enforcement of their respective statutes. However, in undertaking to bal*180anee these interests, I would conclude that the interest of Alabama outweighs the interest of Michigan.
First, I do not believe that Michigan has an interest in affording to an Alabama resident greater rights of recovery for an automobile accident occurring within Alabama than those afforded by Alabama itself. Farrell v Ford Motor Co, 199 Mich App 81, 94; 501 NW2d 567 (1993).
Second, I do not believe that the decedent, a lifelong Alabama resident, would have had any expectation that, should she ever be injured or killed in an automobile accident on an Alabama highway, her lawsuit would be brought under the auspices of Michigan. Such expectations, while not dispositive of the issue, are relevant to the determination which state has a greater interest in the application of its own law. For plaintiff to be able to take advantage of Michigan law, a law which under the present circumstances is the more potentially remunerative one, can only be described as a windfall.
Third, Michigan’s interest is not limited to its concern that vehicle owners take care in entrusting their vehicles to others. Rather, Michigan also has an interest in ensuring that vehicle owners and others doing business in the state are treated in an equitable fashion in disputes with out-of-state parties. To allow an Alabama resident to sue a Michigan business for an accident that occurred in Alabama under terms that are more favorable tiran those under which the resident would be able to sue an Alabama business implicates and is detrimental to this Michigan interest.
Fourth, although Michigan has an interest in the broad application of its owners’ liability statute, its marginal interest in the out-of-state applicability of *181the statute is less substantial than Alabama’s interest in the applicability of its own statute to accidents arising on its own highways resulting in injuries to its own citizens. To the extent that Alabama law is deemed to be applicable to the present circumstances, with a concomitant reduction in the application of Michigan’s owners’ liability statute, I believe that such a reduction would be slight. The proportion of total out-of-state miles driven to total miles driven by Michigan motor vehicles is doubtlessly quite small. As a result, I believe that few owners of Michigan vehicles would exercise less care in the supervision of their vehicles. Further, to the extent that accidents involving Michigan vehicles driven out-of-state are much less likely to involve other Michigan vehicles, or Michigan pedestrians, the interest of Michigan grows less substantial and the interest of the other state grows more substantial.
Fifth, I note the following language in Olmstead-.
The cases in which the plaintiff was not a resident, but brought suit in Michigan . . . have generally applied lex loci delicti, either through a strict reading of Sexton or by weighing the interests of the states involved. ... In all of those cases, the injury occurred in states in which the plaintiff had substantial contacts or actually resided in fact at the time of injury. [Id. at 23.]
In other words, Sexton needs to be placed in context. In Sexton, both the plaintiff and the defendant were Michigan residents. Sexton, supra at 414. In Olmstead, the plaintiff, was not a resident of Michigan or the state in which the accident occurred. Here, plaintiff’s decedent resided in Alabama, the state in which the accident occurred, and had no contact whatsoever with Michigan. Michigan’s interest in the applicability *182of its law, therefore, is considerably diluted; neither Sexton nor Olmstead supports the proposition that the law of Michigan is properly applied here.
Finally, because plaintiff has engaged in forum shopping — seeking to apply the law of a state not that of plaintiffs residence where such application is unnecessary to obtaining jurisdiction over a defendant, Olmstead, supra at 26-27 — I believe that Michigan’s interest in the application of its statute is further diminished. A principal purpose of the choice-of-law rules, in which Michigan also has an interest, is to promote certainty in the determination of which state’s law is to apply and to discourage such forum shopping. Id.; Farrell, supra at 94.
In addition, I would not weigh heavily two factors set forth by the majority in support of its conclusion that the interest of Michigan in applying its law should prevail over those of Alabama. First, the majority contends that Michigan has an interest in “promoting the efficient administration of justice” and resolving the various claims involved in this litigation in a single case with the jury applying a single standard. While this consideration is entitled to some weight, to accord it much weight would simply be to transform the choice-of-law balancing process into a strong presumption that the law of the forum state applies because this factor would virtually always support the law of the forum.1 On virtually any occasion where multiple claims or multiple parties are involved in a lawsuit in which there is a choice-of-law *183dispute, the interest in “promoting the efficient administration of justice” would weigh heavily in favor of the forum state. Further, to accord excessive weight to this consideration would be to afford the plaintiff undue control over which state’s law will apply through the precise formulation of his lawsuit. Ultimately, juries are presumed to be capable of following instructions and applying different legal standards to different cases and claims.
Second, the majority contends that Michigan has an affirmative interest in not applying Alabama law because a similar Michigan law was held to be unconstitutional by the Michigan Supreme Court in 1975 under the Michigan Constitution. I understand Olmstead, to be focused upon the interests of the competing states in applying their own laws, not upon substantive disagreements each might have with the decisions of the other. To engage in the latter analysis recalls the words of one legal scholar in describing earlier legal tendencies in this direction:
And so began a second War Between the States, in which states began casually to denounce each other’s laws as unjust and wrongheaded, and seize on excuses not to enforce them. New York said it had every intention of “protecting its own residents” against “unfair or anachronistic” laws that they might encounter in their travels elsewhere in the United States. [Olson, The Litigation Explosion (Plume, 1992) at 189].
Olsen stated earlier:
[That war] centered on the idea that states with laws discouraging litigation did not always have a strong interest in enforcing those laws. [Id. at 187.]
*184Choice-of-law rules are designed to resolve controversies that inevitably arise about applicable law within a system in which there are multiple sovereigns; such rules are not designed to incite states into second-guessing the substantive wisdom of their sister states. By taking into account this consideration, the majority calls into question both the judgment of the Alabama legislature in enacting their guest passenger statute and the judgment of the Alabama judiciary in failing to evaluate this law under the Alabama constitution in the same manner that the Michigan judiciary evaluated a similar law under the Michigan Constitution. Alabama’s laws are entitled to the same amount of deference by Michigan courts as are the laws of a state whose laws are more closely aligned with those of Michigan. There is no unstated premise in Michigan choice-of-law rules that plaintiffs invariably are entitled to take advantage of those state laws that are most potentially remunerative.
For these reasons, I conclude that the interest of Alabama in having its rules apply to the present case outweighs those of Michigan. The majority opinion would apply Michigan law in an unprecedentedly broad manner and to a controversy in which another state has a significantly greater and more direct interest. Therefore, I would affirm the decision of the trial court.
While it might be said that Olmstead establishes a presumption in favor of the application of the law of the forum, all that it expressly sets forth is that each case be evaluated on the circumstances presented and that there be some rational reason to apply the law of the nonforum state.