Reich v. Purcell

In Reich v. Purcell (1967) 67 Cal.2d 551, an Illinois resident sued a California resident in California in an action arising out of a car accident that occurred in Missouri. Although Missouri was properly concerned with conduct within its borders, the laws controlling how damages for past conduct are calculated had nothing to do with controlling future conduct. "The state of the place of the wrong has little or no interest in such compensation when none of the parties reside there." (Id. at p. 556.) In Reich v. Purcell, the law of three states was potentially involved. The accident occurred in Missouri; the decedent and the plaintiffs resided in Ohio; and the defendant was a resident of California. (See 67 Cal.2d at pp. 552, 555-556.) Notwithstanding the fact that California was the forum and that the plaintiffs had become California residents after the accident, the court held that no legitimate interest of the State of California would be served by applying California's own domestic rule of damages. (67 Cal.2d at pp. 555-556.)