The law on "choice of law" in the various states and in the federal courts is a veritable jungle, which, if the law can be found out, leads not to a "rule of action" but a reign of chaos dominated in each case by the judge's "informed guess" as to what some other state than the one in which he sits would hold its law to be.
Products move today in streams of commerce which cross state, and often international, boundaries. When litigation concerning the liability for injury or damage caused by these products follows, choice of law plays a crucial role in determining the rights, remedies, and defenses available to the parties. In this article, the authors identify the issues which plaintiffs and defendants should consider in multi-jurisdictional product liability actions and set forth the basic rules for tort and contract choice of law.
Digges, Edward S. Jr. and Wharton, Michael T.
"Choice of Law in Product Liability Actions: Order for the Practitioner in a Reign of Chaos,"
University of Baltimore Law Review: Vol. 12
, Article 2.
Available at: http://scholarworks.law.ubalt.edu/ublr/vol12/iss3/2