Bocoum v. Daimler Trucks North America LLC

Background

Oumarou Bocoum brought a product-liability action against Daimler Trucks North America LLC and ZF Active Safety and Electronics US LLC. The opinion states that the case is in federal court under diversity jurisdiction, which allows a federal court to hear certain disputes involving parties connected to different states. The accident occurred in Massachusetts. Bocoum is a New York resident. The defendants are Delaware limited liability companies whose sole members are Delaware corporations with principal places of business in Oregon and Michigan, respectively. The vehicle appears to have been sold to Bocoum’s employer in New Jersey.

Choice of Law

Because the case is based on state-law claims in federal court, the court explained that it must use New York’s rules for choosing which state’s law applies. For tort claims involving rules that regulate conduct, New York generally applies the law of the place where the injury occurred because that jurisdiction has the strongest interest in regulating conduct within its borders. The court stated that, because the accident and injury occurred in Massachusetts, Massachusetts law would appear to govern. The parties’ summary-judgment briefs, however, applied New York law.

Order

The court ordered the parties to file supplemental briefs by January 28, 2022. The briefs must address which state’s law governs the dispute and, if New York law does not apply, how that affects the parties’ summary-judgment arguments. The parties must also explain why venue—the proper federal court location for the case—lies in the Southern District of New York and whether transferring the case to another district may be appropriate. The order did not decide the choice-of-law issue, the venue issue, or the summary-judgment motions.