Bell Helicopter Textron, Inc. v. Arteaga

Bell Helicopter Textron Inc. appealed a Superior Court order determining that Texas law should govern litigation involving a helicopter that crashed in Mexico in 2010. Despite the presumption in the Restatement (Second) of Conflicts that the law of the place where the injury occurred should govern the dispute, the Superior Court found that Texas law had the most significant relationship to the liability, damages, and remedies at issue. The court also opined that Texas law would be easier to apply than Mexican law because there would be no need to hire interpreters. In this interlocutory appeal to the Delaware Supreme Court, Bell argued that Mexican law was more appropriate because the decedents were all Mexican citizens, their relatives bringing this suit are all Mexican citizens, the helicopter was owned by a Mexican company, and it had been operated solely within Mexico for over thirty years when it crashed. Because the governing Restatement test to determine which sovereign's law to apply strongly favors Mexico, the Delaware Court reversed: in this case, those principles unambiguously favor applying Mexican law to the liability, damages, and remedies at issue. View "Bell Helicopter Textron, Inc. v. Arteaga" on Justia Law