## Facts

- Reynolds Alley, a Pennsylvania resident, was injured on January 19, 2015, when a plastic tire rim on an MTD snow thrower burst while he was seating and/or inflating the tire.
- Alley bought and used the snow thrower only in Pennsylvania, and the injury occurred in Pennsylvania.
- MTD’s principal place of business was in Ohio, and the snow thrower was designed, engineered, manufactured, and tested in Ohio.
- Alley sued MTD entities in the Western District of Pennsylvania, asserting product-liability claims (including strict liability) and negligence.
- MTD argued the action was barred by Ohio’s ten-year product-liability statute of repose, which would apply if Ohio law governed under Pennsylvania choice-of-law rules.
- The district court denied summary judgment on the repose defense, later held after trial that Pennsylvania law applied, denied MTD’s renewed judgment-as-a-matter-of-law motion, and added Pennsylvania delay damages to the verdict.

## Issues

1. Whether Pennsylvania choice-of-law principles required applying Ohio’s ten-year statute of repose for product-liability actions, which would bar the claims.
2. Whether Pennsylvania, which lacks a comparable product-liability statute of repose, had the most significant relationship to the occurrence and the parties.

## Decision

- The Third Circuit affirmed the post-trial denial of MTD’s renewed motion for judgment as a matter of law based on the statute-of-repose defense.
- The court held there was a true conflict between Ohio law (statute of repose) and Pennsylvania law (no comparable repose bar for product-liability claims).
- Applying Pennsylvania’s interest-analysis approach and the Restatement (Second) of Conflict of Laws, the court concluded Pennsylvania law governed because Pennsylvania had the most significant relationship to the dispute.
- Because Pennsylvania law applied, Ohio’s ten-year statute of repose did not bar Alley’s claims.

## Legal Principles

- Under Pennsylvania choice-of-law rules for torts, a true conflict is resolved through a qualitative assessment of contacts and governmental interests, consistent with Restatement (Second) of Conflict of Laws §§ 145 and 146.
- In personal-injury product cases, significant contacts include the plaintiff’s residence, where the product was purchased and used, and where the injury occurred, as well as where the product was designed and manufactured.
- A forum state’s interest in compensating residents injured within its borders may outweigh a manufacturing state’s interest in limiting liability through a statute of repose, depending on the location of purchase, use, and injury.
- When the selected governing law lacks a statute of repose applicable to the claims, a foreign state’s repose statute does not apply to bar the action.

## Conclusion

The Third Circuit held that Pennsylvania had the most significant relationship to Alley’s injury and claims because the purchase, use, and injury occurred in Pennsylvania to a Pennsylvania resident, so Pennsylvania law governed and Ohio’s ten-year product-liability statute of repose did not bar recovery.


Alley v. MTD Prods., Inc., 819 F. App'x 95 (3d Cir. 2020)