Woodward v. Taylor
184 Wash. 2d 911
| Wash. | 2016Background
- Single-car rollover in Idaho on March 27, 2011; Washington residents were traveling from Nevada to Washington; icy conditions; driver (Taylor) had cruise control at 82 mph and lost control; rear-seat passenger (Woodward) injured.
- Woodward sued Taylor for negligence in King County, Washington on May 8, 2013 (more than two years after the accident).
- Complaint alleges only that Taylor drove "too fast for the conditions" (general negligence), not negligence per se or family-car theories.
- Trial court dismissed under Idaho’s two-year statute of limitations, reasoning Idaho substantive law applied because the accident occurred in Idaho; Court of Appeals affirmed relying on Ellis.
- Washington Supreme Court granted review and considered whether Washington or Idaho law governs, focusing on conflict-of-laws analysis and whether an "actual conflict" exists.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which state’s substantive law applies? | Washington law presumptively applies to suits filed in Washington; no actual conflict exists. | Idaho law applies because accident occurred in Idaho and claims implicate Idaho rules of the road. | Washington law applies because there is no actual conflict of substantive law under the complaint. |
| Does an actual conflict of law exist between Washington and Idaho here? | No — negligence standard, hazardous-speed rules, and outcome on comparative fault are the same under alleged facts. | Yes — differences in speed limits and comparative fault regime create conflict. | No actual conflict: statutes and outcome would be the same given the complaint’s allegations. |
| If conflict exists, which choice-of-law test controls? | N/A (no conflict) — but if needed, apply Restatement (Second) most significant relationship test. | N/A | Court reiterates two-step approach: identify actual conflict, then apply Restatement factors if conflict exists. |
| Which statute of limitations governs? | Washington’s three-year statute applies because Washington substantive law governs. | Idaho’s two-year statute applies if Idaho substantive law governs. | Washington’s statute applies; claim is not time-barred. |
Key Cases Cited
- Burnside v. Simpson Paper Co., 123 Wn.2d 93 (1994) (forum law presumptively applies when plaintiff files in Washington)
- Rice v. Dow Chem. Co., 124 Wn.2d 205 (1994) (differences in limitation periods alone do not create an actual conflict)
- Seizer v. Sessions, 132 Wn.2d 642 (1997) (actual conflict requires differing outcomes under interested states’ laws)
- Ellis v. Barto, 82 Wn. App. 454 (1996) (Court of Appeals applied most significant relationship test where an actual conflict existed)
- Williams v. Leone & Keeble, Inc., 171 Wn.2d 726 (2011) (use Restatement sections 145–146 contacts for tort choice-of-law analysis)
- Southwell v. Widing Transp., Inc., 101 Wn.2d 200 (1984) (evaluate significance of contacts and state interests under Restatement factors)