65 N.Y.2d 189 (1985)
When faced with conflicting loss-distribution rules in multi-state tort actions, the law of the common domicile should generally apply, unless the locus of the tort has a significant interest and application of its law would advance relevant substantive law purposes.
Summary
Plaintiffs, New Jersey domiciliaries, sued the Boy Scouts of America and the Franciscan Brothers in New York, seeking damages for sexual abuse of their sons by a troop leader at a New York camp. The court addressed a choice-of-law issue, as New Jersey recognized charitable immunity while New York did not. The court held that New Jersey law applied, barring the plaintiffs’ claims due to collateral estoppel from a prior New Jersey judgment. This decision emphasized the significance of the parties’ common domicile in loss-distribution conflicts, particularly when the locus state’s interest is minimal.
Facts
The Schultz family, residents of New Jersey, brought suit against the Boy Scouts of America and the Franciscan Brothers for the sexual abuse of their sons by Edmund Coakeley, a teacher and scout leader. Coakeley abused the sons during scout trips to Pine Creek Reservation in New York. The plaintiffs alleged negligent hiring and supervision by the defendants. One son, Christopher, committed suicide allegedly as a result of the abuse. The Boy Scouts maintained their national headquarters in New Jersey at the time of the abuse.
Procedural History
The plaintiffs filed suit in New York. Defendants moved for summary judgment, arguing that New Jersey’s charitable immunity statute barred the claims and that collateral estoppel applied due to a prior New Jersey judgment against the Roman Catholic Archdiocese. Special Term granted the motion, dismissing the complaint. The Appellate Division affirmed.
Issue(s)
1. Whether New Jersey law should apply to an action involving co-domiciliaries of New Jersey when the tortious acts were committed in New York.
2. Whether the New Jersey charitable immunity statute should be enforced, considering New York’s public policy against charitable immunity.
3. Whether the plaintiffs are collaterally estopped from relitigating the application of the New Jersey charitable immunity statute because of a prior New Jersey judgment.
Holding
1. Yes, because in cases involving loss-distribution rules, the jurisdiction of common domicile is favored, especially when the locus state’s interest is minimal.
2. No, not explicitly decided, but the Court impliedly held no, but found insufficient contacts between New York, the parties, and the transactions to implicate New York’s public policy.
3. Yes, because the issue was actually litigated and determined by a final judgment in New Jersey, that determination was essential to the judgment, and the plaintiffs had a full and fair opportunity to litigate the issue in the prior proceeding.
Court’s Reasoning
The court applied interest analysis, focusing on the purpose of the laws in conflict. It distinguished between conduct-regulating rules, where the locus jurisdiction typically has a predominant interest, and loss-distributing rules, where the common domicile’s interest is greater. The court reasoned that New Jersey’s charitable immunity statute was a loss-distributing rule, reflecting a policy decision to protect charitable organizations. Since the plaintiffs and the Boy Scouts shared a common domicile in New Jersey, and the plaintiffs were beneficiaries of the Boy Scouts’ charitable activities in New Jersey, New Jersey law applied. The court found New York’s deterrent interest diminished because none of the parties were residents and the rule was loss-allocating. The court noted reasons supporting consistent application of the common-domicile law: reduction of forum-shopping, rebutting forum bias, and promoting mutuality and predictability. As for the Franciscan Brothers, the court applied the third Neumeier rule, holding that the law of the place of the tort will normally apply unless displacing it would advance the relevant substantive law purposes without impairing the smooth working of the multi-state system or producing great uncertainty for litigants. Regarding public policy, the court acknowledged New York’s rejection of charitable immunity but found insufficient contacts between New York, the parties, and the transactions to implicate New York’s public policy. Finally, the court upheld the application of collateral estoppel, as the New Jersey courts had already determined the effect of the charitable immunity statute on the plaintiffs’ claims.