Morgan v. Biro Mfg. Co., Inc

In Morgan v. Biro Mfg. Co., Inc. (1984), 15 Ohio St.3d 339, 341-342, 15 Ohio B. 463, 474 N.E.2d 286, the Ohio Supreme Court adopted the Restatement of the Law 2d, Conflict of Laws, which outlines the analysis for determining choice-of-law in a tort action. The court held the following: "When confronted with a choice-of-law issue in a tort action under the Restatement of the Law of Conflicts view, analysis must begin with Section 146. Pursuant to this section, a presumption is created that the law of the place of the injury controls unless another jurisdiction has a more significant relationship to the lawsuit. To determine the state with the most significant relationship, a court must then proceed to consider the general principles set forth in Section 145. The factors within this section are: (1) the place of the injury; (2) the place where the conduct causing the injury occurred; (3) the domicile, residence, nationality, place of incorporation, and place of business of the parties; (4) the place where the relationship between the parties, if any, is located; (5) any factors under Section 6 of the Restatement of the Law of Conflicts which the court may deem relevant to the litigation."