Sinnott v. Thompson
2011 Del. LEXIS 612
Del.2011Background
- Sinnott and Pepper (Delaware residents) challenge applying Delaware law to a North Carolina one-car crash involving Sinnott driving a Delaware-registered vehicle.
- Thompson, a Delaware resident suing on injuries from the North Carolina accident, seeks Delaware law on comparative negligence.
- The Superior Court held Delaware law (comparative negligence) applies, over North Carolina contributory negligence.
- The accident occurred in North Carolina; Sinnott pled guilty to driving while impaired.
- Sinnott and Pepper rely on Restatement sections 145(1)-(2) and 6 to argue the most significant relationship favors North Carolina.
- Delaware has a strong public policy against treating contributory negligence as a complete bar, supporting Delaware law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which state has the most significant relationship for Thompson’s negligence claim | Thompson emphasizes Delaware ties (residents, license, vehicle); contact quality matters | North Carolina location and conduct dominate; injuries centered there | Delaware law applies to Thompson’s negligence claim. |
| Which state governs Pepper’s negligent entrustment claim | Delaware has strongest ties; entrustment originated in Delaware | Policy and interstate system considerations favor Virginia/NC; but primarily Delaware interests dominate | Delaware law applies to Thompson’s negligent entrustment claim against Pepper. |
Key Cases Cited
- Travelers Indem. Co. v. Lake, 594 A.2d 38 (Del. 1991) (adopts most significant relationship test; damages context in that case)
- State Farm Mut. Auto. Ins. Co. v. Patterson, 7 A.3d 454 (Del. 2010) (declined to apply injury-state law when forum policy prevails)
- Conlin v. Hutcheon, 560 F. Supp. 934 (D. Colo. 1983) (illustrates contacts favoring home-state law for choice-of-law)
- Turner v. Lipschultz, 619 A.2d 912 (Del. 1992) (distinguishes when conduct and injury occur in different contexts)
- Yoder v. Delmarva Power & Light Co., 976 A.2d 172 (Del. 2009) (illustrates application of choice-of-law principles to damages/entrustment context)