In this action arising out of a fatal motor vehicle accident, where there is an actual conflict between the laws of New Jersey and Pennsylvania, the decedent was a Pennsylvania resident, the accident occurred in New Jersey, the defendants are all New Jersey residents, and the decedent's presence in New Jersey was not merely fortuitous, under the governmental-interest analysis, New Jersey has the greater interest in seeing its law applied and the survivor's claim will be governed by that state's law.
October 25, 2004 at 12:00 AM
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