In Neumeier v. Kuehner, 31 NY2d 121, 128, 286 N.E.2d 454, 335 N.Y.S.2d 64 (1972), the Court of Appeals held that where: (1) the conflicting state statutes involve loss allocation; (2) the parties are domiciled in different states from each other; (3) no party is domiciled in the state where the accident occurred, the law of the situs of the tort should apply unless "it can be shown that displacing that normally applicable rule will advance the relevant substantive law purposes without impairing the smooth working of the multi-state system or producing great uncertainty for litigants."