mexico flagthBell Helicopter Textron, Inc. v. Arteaga, No. 333,2014 (Del. Supr., Apr. 6, 2015). This Delaware Supreme Court decision provides a useful application of principles that determine which jurisdiction’s laws apply to a particular suit with facts involving multiple fora. This split opinion concludes that the law of Mexico should apply to a lawsuit pending in Delaware state court involving the crash of a helicopter that was manufactured in Texas, primarily because the crash occurred in Mexico and all of the victims of the crash were residents of Mexico. Also featured is a somewhat rare dissent from an en banc Supreme Court. The trial court had applied Texas law. At oral argument, the plaintiff’s lawyer stated that he chose Delaware as a forum based on the state of incorporation of the defendant, even though no party argued that Delaware law applied.

The internal affairs doctrine was mentioned in passing, but it did not apply because this case did not involve a dispute among stockholders or directors and the corporation.