Duke v. Housen
Supreme Court of Wyoming
589 P.2d 334 (1979)
Margaret Housen (plaintiff) and "Pony" Duke (defendant) had a relationship involving sexual contact across several states during a road trip; after their final encounter in New York, Duke told Housen he had gonorrhea, and she was diagnosed with the disease days later in D.C. In 1973 she developed abdominal adhesions from the infection, and in 1974 she sued Duke for negligence in Wyoming, more than three years after learning of her infection but within Wyoming's own four-year limitations period. Duke argued the suit was time-barred under the shorter limitations period of wherever the injury actually occurred; the trial court applied Wyoming's four-year period (running from discovery of the adhesions) and affirmed a $1.3 million jury verdict for Housen. Duke appealed.
Whether the forum state applies the statute of limitations of the state in which the cause of action accrued, rather than its own.