Barrett v. Ambient Pressure Diving

2008 DNH 199
CourtDistrict Court, D. New Hampshire
DecidedNovember 17, 2008
Docket06-CV-240-SM
StatusPublished
Cited by1 cases

This text of 2008 DNH 199 (Barrett v. Ambient Pressure Diving) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barrett v. Ambient Pressure Diving, 2008 DNH 199 (D.N.H. 2008).

Opinion

Barrett v . Ambient Pressure Diving 06-CV-240-SM 11/17/08 P UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Stephanie B . Barrett, individually; and as Administratrix of the Estate of Robert C . Barrett, deceased; and as natural mother of Madison Hope Barrett, a minor, Plaintiff Civil N o . 06-cv-240-SM v. Opinion N o . 2008 DNH 199

Ambient Pressure Diving, Ltd., Defendant

O R D E R

Defendant has filed a supplemental motion for application of

English law. Defendant concedes that English law and New

Hampshire law are substantially similar with regard to the

liability aspects of plaintiff’s various causes of action, and

agrees to the application of New Hampshire law to all liability

questions.1 But, based on differences between the damages

available under the two legal schemes, defendant asks the court

t o : “(1) bar the request for hedonic damages on any of the

Plaintiff’s claims; and (2) bar the request for multiplied

damages on the Plaintiff’s Unfair Trade Practices claim, as no

such multiplication of damages is permitted under English

1 Defendant’s proposed jury instructions on strict liability, negligent design, and unfair and deceptive trade practices all describe New Hampshire law. Consumer Protection statutes.”2 Defendant has subsequently

identified two additional aspects of English law from which it

seeks to benefit — the unavailability of damages for loss of

consortium, see Massaquoi v . Virgin Atl. Airways, 945 F . Supp.

5 8 , 61 ( S . D . N . Y . 1996), and the English cost-shifting rule under

which “the prevailing party can generally recover its attorneys’

fees from the losing party,” R L S Assocs., L L C v . United Bank of

Kuwait P L C , 464 F . Supp. 2d 206, 210 ( S . D . N . Y . 2006).

Plaintiff objects, and asks the court to apply New Hampshire

law, which: ( 1 ) permits the recovery of hedonic damages in

wrongful death cases, see Marcotte v . Timberlane/Hampstead Sch.

Dist., 143 N . H . 3 3 1 , 336-345 (1999); ( 2 ) allows for an award of

double or treble damages in private actions brought under the

Consumer Protection Act, see N . H . R E V . S T A T . A N N . ( “ R S A ” ) § 358-

A : 1 0 , I ; ( 3 ) permits spouses and minor children to recover in

wrongful-death cases, see R S A 556:12, I I & I I I ; and ( 4 ) follows

the American rule, under which “each party is responsible for

paying his or her own counsel fees” unless there is “statutory

authorization [to the contrary], a court rule, an agreement

2 English law does, indeed, bar the recovery of hedonic damages in wrongful death cases, see Administration of Justice Act, 1982, c. 5 3 , § 1(1)(a), and would appear to bar the recovery of punitive or exemplary damages in product liability cases, see Broom v . Cassell & Co., (1972) App. Cas. 1027 (citing Rookes v . Barnard, (1964) App. Cas. 1129)).

2 between the parties, or an established exception [to the general

rule].” In re Martel, 157 N.H. 5 3 , 63 (2008) (citing In re

Hampers, 154 N.H. 275, 289 (2006)).

The choice-of-law question presented here is somewhat

complicated. The plaintiff’s decedent, a Maryland resident, died

while diving in Pennsylvania, using a rebreather manufactured in

England, imported to North America through Canada, and purchased

by the decedent through a New Hampshire dive shop. Plaintiff

initially brought this suit in the District of Pennsylvania.

Venue was subsequently transferred to this court, given the lack

of personal jurisdiction over Ambient in Pennsylvania.

There are substantive differences between English damages

law and New Hampshire law. Accordingly, a choice-of-law analysis

is necessary. See Royal Bus. Group, Inc. v . Realist, Inc., 933

F.2d 1056, 1064 (1st Cir. 1991). New Hampshire’s choice-of-law

rules apply. See Klaxon C o . v . Stentor Elec. Mfg. Co., 313 U.S.

487, 496 (1941). (While there is some authority for the

proposition that a court adjudicating a case that has been

transferred to it should apply the choice-of-law rules of the

jurisdiction from which the case was transferred, see CPC Int’l,

Inc. v . Northbrook Excess & Surplus Ins. Co., 46 F.3d 1211, 1213

(1st Cir. 1995), that proposition would seem inapplicable where,

3 as here, the transferring court lacked personal jurisdiction over

the defendant.)

The choice-of-law analysis is not, of course, limited to

consideration to the two options suggested by the parties. See

LaBounty v . Am. Ins. Co., 122 N.H. 7 3 8 , 741 (1982) (“While

Thompson urges that New Hampshire law should be applied and

LaBounty contends that Massachusetts law should control, we will

not be restricted to the choice of the parties where it is clear

that the interests of another State – Maine – are also

involved.”). 3 Because Robert Barrett was a resident of Maryland

at the time of his death, and the plaintiff is currently a

resident of that state, due consideration must be given to the

application of Maryland law, notwithstanding the fact that

neither party seeks its application. See id. That Robert

Barrett died in Pennsylvania gives rise to that state’s interest

in the liability aspect of the case, but it is difficult to see

what compelling interest Pennsylvania might have with respect to

3 Pennsylvania appears to follow a similar rule. See Commonwealth v . Eichinger, 915 A.2d 1122, 1133 (Pa. 2007) (citing Commonwealth v . Ohle, 470 A.2d 6 1 , 68 (Pa. 1983)) (“where more than one state has a substantial connection with the activity in question, the forum state may analyze the interests of all states involved and choose which state’s law to apply”) (emphasis added).

4 the damages a Maryland citizen might recover from an English

defendant.

The New Hampshire Supreme Court “has rejected the

traditional lex loci delicto rule that the law of the forum where

the injury occurs is paramount.” LaBounty, 122 N.H. at 741.

Rather, conflict-of-law questions are resolved by weighing five

choice-influencing considerations:

(1) predictability of results; (2) maintenance of reasonable orderliness and good relationship among the States in our federal system; (3) simplification of the judicial task; (4) advancement by the court of its own State’s governmental interests rather than those of other States; and (5) the court’s preference for what it regards as the sounder rule of law.

Lessard v . Clarke, 143 N.H. 555, 556 (1999) (quoting Ferren v .

Gen. Motors Corp., 137 N.H. 423, 425 (1993)). 4

4 For its part, Pennsylvania employs a “flexible choice of law rule which weighs the interests [all] states [involved] may have in the transaction.” Eichinger, 915 A.2d at 1133 (citing Griffith v . United Air Lines, Inc., 203 A.2d 796, 805 (Pa. 1964)). As the Pennsylvania Supreme Court explained in Griffith:

[A]fter careful review and consideration of the leading authorities and cases, we are of the opinion that the strict lex loci delicti rule should be abandoned in Pennsylvania in favor of a more flexible rule which permits analysis of the policies and interests underlying the particular issue before the court. As said in Babcock v .

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Bluebook (online)
2008 DNH 199, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barrett-v-ambient-pressure-diving-nhd-2008.