WA Case Update: When Statutes of Limitations Conflict, Which State’s Law Applies?

From the desk of Kyle Riley: When determining which states’ substantive laws to apply, will differing statutes of limitations between two states create a conflict of law?

Claims Pointer: The Washington Supreme Court concluded that different statutes of limitations between Washington and Idaho will not support an actual conflict of law. After reviewing the relevant laws of each state, the Court determined that the outcome of Woodward’s negligence claim in either state would be the same, namely Taylor being liable to Woodward. The Court held that different statutes of limitations in two different states do not establish a conflict of law and further rejected the proposition that the law of the state where the accident occurred presumptively applied.

Woodward v. Taylor, No. 91270-0 (January 14, 2016).

Ava Taylor was driving a car through Idaho with three passengers, including Claire Woodward. Both Taylor and Woodward were residents of Washington and were on their way back to Washington. The Idaho roadway was slick with ice, and snow was visible on the side of the road. Despite these conditions, Taylor set her cruise control to 82 mph—above the legal speed limit of 75 mph. Taylor lost control of the car, resulting in a rollover accident. Though Woodward was wearing a seatbelt, she suffered significant injuries, including a complex comminuted fracture to her neck.

Woodward filed a negligence suit against Taylor in Washington Superior Court. Woodward alleged that Taylor was negligent in driving too fast for the conditions of the roadway at the time and place of the one-car, roll-over collision. Taylor moved to dismiss, arguing Woodward’s claim was time barred under Idaho’s two year statute of limitations for personal injury actions. The trial court agreed with Taylor and dismissed the suit, providing that the negligence action is subject to the law of the state where the accident occurred. The Court of Appeals agreed with the trial court and affirmed the...

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