## Facts

- Steven Pfau, a Connecticut domiciliary, was a student at Parsons College in Iowa.
- Bruce Trent, a New Jersey domiciliary and college student, owned and operated a car with the consent of Trent Aluminum Company, a New Jersey corporation owned by his father.
- The car was registered in New Jersey and insured there by a New Jersey insurer.
- After Easter vacation in 1966, Trent drove the car from New Jersey to Iowa for use at school.
- On April 22, 1966, Trent agreed to drive Pfau from Iowa to Columbia, Missouri, for a weekend trip.
- Shortly after leaving the college in Iowa, Trent failed to negotiate a curve and collided with an oncoming vehicle, injuring Pfau.
- Iowa had an automobile guest statute limiting a host driver’s liability to guests to willful and wanton misconduct, barring recovery for ordinary negligence.

## Issues

1. When a New Jersey court considers applying another state’s substantive law, must it also apply that state’s choice-of-law rules (renvoi)?
2. In a multistate host–guest accident involving a Connecticut guest, New Jersey host/owner/insurance, and an Iowa injury location with a guest statute, which state’s substantive law governs host–guest liability?

## Decision

- The Supreme Court of New Jersey reversed the Appellate Division and reinstated the trial court’s order striking the Iowa-guest-statute defense.
- The court held New Jersey may apply a foreign state’s substantive law without importing that state’s choice-of-law rules; renvoi was rejected.
- Applying governmental-interest analysis, the court concluded Iowa’s guest statute should not govern this dispute.
- Because New Jersey and Connecticut both imposed ordinary-care liability for host drivers (no guest statute), there was no meaningful substantive conflict between the states most connected to the parties.

## Legal Principles

- A forum may apply another state’s substantive law without adopting that state’s conflicts rules; foreign choice-of-law rules are not themselves substantive governmental policies.
- Under governmental-interest analysis, the forum identifies the policies served by each involved state’s law and asks whether those policies are implicated by the parties and events before the court.
- The law of the place of injury may be discounted when its connection is largely the fortuitous location of the accident and its policy objectives are not materially advanced by application to nonresidents.
- When the laws of the states with genuine connections are materially identical on the disputed issue, the case presents no true substantive conflict requiring selection between those laws.

## Conclusion

The court rejected renvoi and, using governmental-interest analysis, refused to apply Iowa’s guest statute to a Connecticut guest’s claims against New Jersey defendants, allowing the case to proceed under an ordinary-negligence standard.


Pfau v. Trent Aluminum Co., 55 N.J. 511, 263 A.2d 129 (N.J. 1970)