Edwards v. Erie Coach Lines Company
Court of Appeals of New York
952 N.E.2d 1033 (N.Y. 2011)
A bus crashed into a truck near Geneseo, New York, killing three bus passengers and the truck driver and injuring other bus passengers; the bus driver, his company, and the leasing company (bus defendants) were domiciled in Ontario, like the injured plaintiffs, while the truck driver, his company, and the hiring company (truck defendants) were domiciled in Pennsylvania. The Ontario-domiciled plaintiffs sued in New York, arguing the court should analyze the bus and truck defendants jointly for choice-of-law purposes and apply New York law (which had no damages cap) rather than Ontario law (which capped damages). The trial court applied a single joint analysis and found Ontario law governed both sets of claims; the Appellate Division instead analyzed the bus and truck defendants separately but still found Ontario law applied to both.
Whether, in a choice-of-law analysis involving multiple plaintiffs and defendants, a court may conduct a single joint analysis covering all parties together, rather than analyzing each plaintiff against each defendant individually.