Chen v. Los Angeles Truck Centers, LLCAnnotate this Case
In this tort action arising out of a fatal tour bus accident in Arizona, the Supreme Court held that the trial court did not err by declining to reconsider its prior choice of law ruling after an Indiana defendant was dismissed from this case.
The parties in this case initially included plaintiffs from China and defendants from both Indiana and California. The trial court conducted the governmental interest test and concluded that Indiana law governed. Before trial, Plaintiffs accepted a settlement offer from the Indiana defendant. The court of appeals reversed, concluding that the trial court should have reconsidered the initial choice of law ruling after the Indiana defendant was dismissed from the case. The court then applied the governmental interest test and concluded that California law governed. The Supreme Court reversed, holding (1) given the importance of determining the choice of law early in a case, the circumstances in which trial courts are required to revisit a choice of law determination should be the exception and not the rule; and (2) the trial court in this case was not required to reconsider the prior choice of law ruling based on the Indiana defendant's settlement.