## Facts

- Helmut Bohm, an employee of the University of Nevada–Reno, drove a university-owned vehicle into California on official university business.
- While returning on Interstate 80 near Penryn, California, during a rainstorm, Bohm’s vehicle crossed into oncoming traffic and collided with a car occupied by John and Patricia Hall, their three children, and another passenger.
- The occupants of the Hall vehicle were California residents; all were injured. Bohm was killed.
- The injuries were severe, including long-term brain injury and developmental impairments to the Halls’ youngest child and brain damage to Patricia Hall.
- The Halls first sought compensation through Nevada’s administrative claims process, but Nevada’s Board of Examiners denied the claim.
- The Halls then sued in California state court, naming Nevada (and related Nevada entities) based on the negligent operation of the Nevada-owned vehicle in California.
- Nevada had waived sovereign immunity by statute but asserted that its waiver was limited by a Nevada law capping tort damages against the state at $25,000 per person.
- Nevada moved the California trial court to apply the Nevada damages cap; the trial court denied the motion and applied California damages law.
- A jury awarded approximately $1.15 million in total damages to the plaintiffs.
- Nevada appealed, arguing that full faith and credit (and related doctrines) required California to enforce Nevada’s damages limitation.

## Issues

1. Whether the Full Faith and Credit Clause required a California court to apply Nevada’s $25,000-per-person statutory damages cap in a California tort action against Nevada arising from an automobile collision on a California highway.
2. Whether, under California choice-of-law principles and interstate comity, California should displace its own damages rules in favor of Nevada’s liability limitation for claims against Nevada.

## Decision

- The Court of Appeal affirmed the judgment for the plaintiffs.
- The court held that California was not required by the Full Faith and Credit Clause to apply Nevada’s $25,000 damages cap.
- The court approved the trial court’s use of California law to determine damages for injuries resulting from negligent driving in California, even though the defendant was a sister state and the vehicle was being operated on that state’s business.
- The court left undisturbed the jury’s approximately $1.15 million award.

## Legal Principles

- The Full Faith and Credit Clause does not invariably require a forum state to apply another state’s statute when doing so would conflict with the forum’s legitimate public policy as applied to events occurring within the forum.
- A forum state with a strong connection to the occurrence—such as a traffic collision and resulting injuries on its highways—may apply its own tort damages law to provide full compensation.
- A sister state’s statutory limits tied to its waiver of sovereign immunity do not automatically control the measure of damages in another state’s courts for torts committed in the forum.
- Interstate comity may support honoring a sister state’s limitation, but comity is not a constitutional command and may yield when it would substantially impair the forum state’s public policy and local regulatory interests.

## Conclusion

In *Hall v. Nevada [II]*, the California Court of Appeal affirmed a $1.15 million judgment arising from a California highway collision caused by a University of Nevada employee acting on university business, holding that California was not constitutionally required to enforce Nevada’s $25,000-per-person damages cap and could instead apply California damages law to fully compensate those injured in California.


Hall v. Nevada [II], 141 Cal. Rptr. 439, 74 Cal. App. 3d 280 (1977)