Laboratory Corporation of America v. Hood

Maryland residents Karen and Scott Hood (plaintiffs) received prenatal testing from North Carolina-based Laboratory Corporation of America (LabCorp) (defendant), which misread test results in North Carolina and incorrectly reported that their unborn son didn't have cystic fibrosis; he was born with the disease, and the Hoods sued for wrongful birth in federal court in Maryland. The district court applied Maryland's lex loci delicti rule (law of the place of injury), reasoning Maryland was where the last event necessary for the tort occurred, but LabCorp argued a Restatement exception required applying North Carolina's law because that's where its employees' allegedly negligent conduct took place, and North Carolina law didn't allow wrongful-birth claims at all. The district court certified two questions to Maryland's high court: whether the standard-of-care exception applied, and whether applying North Carolina law to bar the claim would violate Maryland public policy.

Whether the law of a forum state controls when a foreign jurisdiction's law on the relevant standard of care conflicts with the forum state's public policy.