Choice of Law In Pennsylvania
In Pennsylvania, the law of the forum governs the time in which a cause of action must be commenced. Unisys Finance Corp. v. U.S. Vision, Inc., 428 Pa. Super. 107, 630 A.2d 55, 58 (Pa. Super. 1993); Gwaltney v. Stone, 387 Pa. Super. 492, 564 A.2d 498, 502 (Pa. Super. 1989).
The borrowing statute, known as the Uniform Statute of Limitations on Foreign Claims Act, 42 Pa. C.S. 5521, establishes the time in which an action accruing out-of-state will be time barred.
Thus, the statute provides a very particular rule for resolving conflicting limitations periods.
However, for resolution of substantive conflicts we must turn to the analysis prescribed under Griffith v. United Air Lines, Inc., 416 Pa. 1, 203 A.2d 796 (1964).
Under Griffith v. United Air Lines, Inc., 416 Pa. 1, 203 A.2d 796 (1964), the choice of law determination looks to the law of the jurisdiction with the most significant relationship to the occurrence and the parties, placing importance on analysis of the policies underlying the conflicting laws and the relationship of the particular contacts to those policies. Id. at 15, 203 A.2d at 802.
Proper application of the analysis depends not on a mere counting of contacts with the respective jurisdictions; the contacts must be measured on a qualitative rather than a quantitative scale. Caputo v. Allstate Ins. Co., 344 Pa. Super. 1, 495 A.2d 959, 961 (Pa. Super. 1985).