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Garcia v. General Motors Corp.5/6/1999
REVERSED AND REMANDED
Defendant General Motors Corporation appeals from an adverse jury verdict arising from a single-car rollover accident in Idaho. General Motors claims that the trial court erred in applying Idaho law, which precluded evidence that Plaintiffs were not wearing their seatbelts at the time of the accident. Because we find that choice-of-law principles dictate the application of Arizona comparative fault law to the facts of this case, we reverse and remand for a new trial.
BACKGROUND
In 1993, Plaintiffs, all Arizona residents and members of a church group, rented a van from Defendant National Car Rental in Phoenix for a trip to a camp near Walla Walla, Washington. While passing through Idaho, the Arizona driver lost control of the van, which ran off the road and overturned. All of the passengers were injured in the accident. Although the van was fully equipped with functional seatbelts, none of the passengers was wearing a seatbelt at the time of the accident. As a result, most of the eleven passengers were ejected from the van. Plaintiffs assert that the accident was caused by a design defect in the van, which was manufactured by Defendant General Motors.
Ilsy Echeverria, one of the passengers in the van, immediately sued General Motors and other defendants in the United States District Court for the District of Idaho. Applying Idaho state law, that court granted Echeverria's motion in limine to exclude all evidence that she failed to wear her seatbelt. The Idaho law provides that " he failure to use a safety belt shall not be considered under any circumstances as evidence of contributory or comparative negligence, nor shall such failure be admissible as evidence in any civil action with regard to negligence." Idaho Code ยง 49-673(6). The court reasoned that Idaho law should apply because the accident occurred in Idaho and Plaintiff had a reasonable expectation that Idaho law would apply to conduct that occurred in that state. The court also noted that Idaho law should apply because of its "ease in determination and application." After this ruling but before trial, Echeverria settled with all of the defendants.
On August 16, 1995, the remaining passengers in the van filed lawsuits in Maricopa County Superior Court against Defendants General Motors, National Car Rental, and Phoenix Tabernacle. Plaintiffs moved to strike General Motors' use of the "seatbelt defense," arguing that the Idaho court's ruling on Echeverria's motion in limine bound General Motors in this case, and regardless of the estoppel effect of the Idaho court's ruling, choice-of-law principles dictated that the court apply Idaho law rather than Arizona law to this case. General Motors responded, arguing that it should not be collaterally estopped from asserting the seatbelt defense because Arizona courts apply choice-of-law principles differently than Idaho courts do, and Plaintiffs' attempted use of collateral estoppel was offensive, not defensive, and therefore improper. The trial court struck General Motors' use of the seatbelt defense and affirmed that the Idaho rule would apply.
The jury returned a verdict for Plaintiffs against General Motors. The trial court denied General Motors' motion for a new trial and General Motors timely appealed, arguing that the trial court erred in applying Idaho law and striking the seatbelt defense. We have jurisdiction over this appeal pursuant to Arizona Revised Statutes Annotated ("A.R.S.") section 12-2101(B) (1994).
DISCUSSION
I. Collateral Estoppel
Plaintiffs contend that the Idaho federal district court's ruling on the choice-of-law issue binds the Ar
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