Federal Court Applies Choice of Law Analysis

In the case of Karabec-Studer v. Avis Rent A Car System, LLC, No. 23-CV3828 (E.D. Pa. March 28, 2025 Kenney, J.), the Eastern District Federal Court completed a choice-of-law analysis in deciding a Defendant’s Motion for Summary Judgment on the Plaintiff’s claims for punitive damages under claims that the Defendant negligently rented a vehicle with issues.

According to the Opinion, the Plaintiff rented a car from Avis and was involved in a motor vehicle accident while traveling through Pennsylvania. The Plaintiff more specifically alleged that the Defendant negligently and recklessly rented them a car with inadequate tire tread. The Plaintiff rented the car in the state of Virginia. 

The Defendant moved for partial summary judgment on the punitive damages issues.

After reviewing the choice-of-law factors, the court concluded that Virginia’s punitive damages law, including that state's cap on damages would apply.

The court otherwise denied the Motion for Partial Summary Judgement after finding that there were genuine issues of material fact as to whether or not the Defendants recklessly disregard the probability that their conduct would result in injury to the Plaintiffs. The court noted that the record indicated that the tire treads were below the Defendant’s standards as well as the legal limits regarding the same.

Anyone wishing to review a copy of this decision may click this LINK.  The Court's companion Order can be viewed HERE.


Source: The Legal Intelligencer Federal Case Alert, www.Law.com (April 24, 2025).