## Facts

- Phillip Alexander, Jr. bought a General Motors vehicle new in Georgia.
- While driving in Virginia, the driver’s seat failed during a collision, allegedly causing his ejection and injuries.
- Alexander sued General Motors in Georgia, asserting strict products liability under O.C.G.A. § 51-1-11.
- The trial court applied lex loci delicti, held Virginia law controlled because the injury occurred in Virginia, and granted partial summary judgment against the strict-liability claim because Virginia does not recognize strict liability in tort; Alexander was permitted to pursue negligence under Virginia law.
- The Georgia Court of Appeals affirmed, reasoning Virginia product-liability law was not so different from Georgia’s as to trigger Georgia’s public-policy exception.
- The Supreme Court of Georgia granted review to decide whether applying Virginia law would contravene Georgia public policy embodied in O.C.G.A. § 51-1-11.

## Issues

1. Whether Georgia’s lex loci delicti rule required application of Virginia substantive law to a products-liability injury occurring in Virginia.
2. Whether Georgia’s public-policy exception bars applying Virginia law when it would preclude a strict-liability claim authorized by O.C.G.A. § 51-1-11 for a product sold new in Georgia.

## Decision

- The Supreme Court of Georgia reversed the Court of Appeals.
- The court held lex loci delicti did not control because applying Virginia law would contravene Georgia public policy expressed in O.C.G.A. § 51-1-11.
- Georgia law, including its strict products liability statute, governed the strict-liability claim.
- The case was remanded for further proceedings consistent with applying Georgia strict-liability law.

## Legal Principles

- Georgia generally applies lex loci delicti to substantive tort issues, using the law of the place where the injury occurred.
- Georgia will refuse to apply otherwise-applicable foreign law if it contravenes Georgia public policy.
- O.C.G.A. § 51-1-11 reflects a legislative policy choice to shift losses from defective products to manufacturers through strict liability, eliminating the need to prove negligence.
- A conflict is sufficient to trigger the public-policy exception when foreign law would deny a cause of action that Georgia law affirmatively provides as a core part of that policy.

## Conclusion

Georgia’s strict products liability statute embodies a public policy that can displace lex loci delicti when foreign law would eliminate strict liability; therefore, Georgia law governed a strict-liability claim for a vehicle purchased new in Georgia even though the injury occurred in Virginia.


Alexander v. Gen. Motors Corp., 267 Ga. 339 (1996)