Erie Insurance Exchange v. Edmund D. Heffernan, Ii

Summary

The court held that an uninsured/underinsured motorist benefits action is contractual in form but requires proof of the underlying tort claim, so Maryland's tort choice-of-law rule governs the issues of fault and damages. Because the accident and injury occurred in Delaware, Delaware substantive tort law applies, including its comparative-negligence principles, while Maryland law governs contract interpretation. Maryland's public-policy exception does not require applying Maryland's non-economic-damages cap or contributory-negligence rule, and the court declined to apply renvoi.