Fear and Loathing In Our Courts: Can Choice of Law be Decided Without Prejudice?

The following is a commentary by Edward R. Hugo of Hugo Parker LLP. For more on the author, please scroll to the bottom of this article.

Fear and Loathing is an ominous title for a commentary on choice of law, but how else do we account for the recent decisions of the Los Angeles Superior Court and the Second Appellate District in Sarooie v. Asbestos Corporation Ltd., et al., (Los Angeles Superior Court, Case No. JCCP 4674/BC529503), in which the defendants have sought, and been denied, application of Iranian law, despite the fact that 29 years of the alleged exposure, …