Amiot v. Ames

Morse, J.,

concurring and dissenting. I concur in the Court’s endorsement of the significant-relationship approach to choice of law. I dissent, however, from its holding that on remand the choice-of-law determination should be made by the trial court. When an issue of fact upon which the choice-of-law decision turns is determinative of an ultimate issue on the merits, resolution of that fact properly rests with a jury. Our Constitution explicitly provides “[tjhat when any issue in fact, proper for the cognizance of a jury is joined in a court of law, the parties have a right to trial by jury, which ought to be held sacred.” Vt. Const, ch. I, art. 12; see Hodgdon v. Mt. Mansfield Co., *297160 Vt. 150, 155, 624 A.2d 1122, 1125 (1992). Although many factual issues involving such preliminary questions as choice of law, jurisdiction, venue, service of process, and discovery may — and should — properly be resolved by a judge, when such an issue is inextricably intertwined with the merits of the case, in my view the Constitution requires that it be resolved by a jury.

That is precisely the situation presented here. Plaintiff has alleged that defendant, a Vermont resident, negligently failed in Vermont to administer the insulin necessary to control his diabetes, causing defendant to lose control of his vehicle in Vermont, cross the border into Quebec, and strike the rear of plaintiff’s automobile. In these circumstances, a consideration of fundamental importance in determining which jurisdiction has the most significant relationship to the occurrence is the place where the conduct causing the injury, that is, the negligent conduct, occurred. Restatement (Second) of Conflict of Laws § 145(2)(b) (1971). Indeed, this factor was given decisive weight in the trial court’s decision to apply Vermont law. As the court explained:

That the site of actual damage was Quebec was merely a coincidence of defendant’s alleged negligence on the Vermont side of the border.
“When [the place] of injury ... is fortuitous and, with respect to the particular issue, bears little relation to the occurrence and the parties, the place where the defendant’s conduct occurred will usually be given particular weight in determining the state of the applicable law.”

(quoting Restatement (Second) of Conflict of Laws § 145 cmt. e).

The trial court’s choice-of-law decision was dispositive of whether plaintiff even had a valid cause of action. If, as the court ruled, Vermont law applied, plaintiff could proceed with his civil action against defendant. If, however, the court had decided that this was simply a “rear-ender” caused solely by defendant’s inattention over the border in Quebec, plaintiff’s case would have been barred by a rule of that province limiting plaintiff to an administrative remedy.

On remand, the trial court is ordered by this Court to reconsider its ruling in light of the facts found in an evidentiary hearing. This can lead to one of two results. If the trial court decides the evidence supports plaintiff’s claim that defendant’s allegedly negligent conduct occurred in Vermont, it will, presumably, make the same choice-of-law decision and allow the case to proceed. Having resolved that factual *298issue, however, the trial court would presumably not allow the issue to be relitigated, but rather would instruct the jury to assume plaintiff’s allegation to be true. Thus, defendant would be denied a jury trial on the ultimate issue in the case. Alternatively, should the trial court conclude that the evidence does not support plaintiff’s claim that defendant failed to administer the insulin in Vermont, the case would presumably be dismissed, and plaintiff would be denied a jury determination on the merits of the ultimate issue.

Thus, this case presents a rare, but nevertheless important occasion to depart from the general rule that threshold determinations of fact necessary to a choice-of-law decision should generally be left to the court. See W. Reese, et al., The Role of the Jury in Choice of Law, 25 Case W Res. L. Rev. 82, 106 (1974) (“[T]he question whether to submit [a fact question] to the jury after the close of evidence should normally be answered in the negative. There may be occasions, however, when . . . the jury is better qualified than [the court] to decide the issue.”).

The Restatement does not address the question whether judge or jury should make such preliminary determinations, and case law is scarce. Nevertheless, there is clear support for the proposition that the jury should prevail when choice-of-law issues and the merits are so “factually meshed” that a “ruling thereon would have disposed of the merits of the[] cause of action, and therefore should have been deferred until a trial on the merits.” Vaz Borralho v. Keydril Co., 696 F.2d 379, 387 (5th Cir. 1983), overruled on unrelated grounds by In re Air Crash Disaster Near New Orleans, La., 821 F.2d 1147 (5th Cir. 1987).

The seminal decision is Marra v. Bushee, 447 F.2d 1282 (2d Cir. 1971). In that case, judgment for the plaintiff was reversed because of the trial judge’s failure in an action for alienation of affections to submit to the jury the question whether the defendant’s conduct had “primarily occurred” in New York or Vermont. Id. at 1283. The defendant, a resident of Vermont, had moved for a directed verdict at the close of the plaintiff’s case, and again at the conclusion of the evidence, asserting that any alienation of affections had occurred in the plaintiff’s home state, New York, which had abolished the cause of action. The trial court disagreed. “On the premise that a factual finding territorializing the defendant’s conduct was a jurisdictional matter not within the province of the jury, the district court itself concluded ‘that the conduct which constituted the alienation occurred principally in Vermont and the applicable law is Vermont law.’” Id. *299The Court of Appeals reversed, holding that where “tort liability turned upon resolution of the choice-of-law question,. . . the defendant was entitled to the jury’s consideration.” Id. at 1284. Marra relied, in turn, upon Orr v. Sasseman, 239 F.2d 182 (5th Cir. 1956), another alienation of affections case in which the situs of the defendant’s conduct, Georgia or Illinois, determined the choice of law, and the viability of the claim. In affirming judgment for the plaintiff, the Sasseman court “expressly approved the trial court’s [jury] instruction that if the loss of consortium occurred in Illinois, the verdict must be for the defendant; but if the claim arose in Georgia there could be a verdict for the plaintiff.” Marra, 447 F.2d at 1284.

Here, similarly, the trial court on remand should be directed to frame a simple jury interrogatory asking whether the defendant was negligent, and if so, whether the negligence occurred in Vermont. If the jury answers both questions in the affirmative, then it may return a verdict for the plaintiff. If it answers either question in the negative, then the verdict must be for defendant. Whatever “efficiency” might be lost through this procedure is more than compensated by the constitutional principle — the right to trial by jury — that it preserves.