Alabama Great Southern Railroad v. Carroll

This case is an example of the First Restatement approach to horizontal choice of law. Under this approach, the state whose laws govern the case is the state in which the “wrong” was complete, i.e., the place of injury. We look to the state in which the last event that vested a plaintiff with the right to sue occurred; this state’s law will govern the substantive issues of the case.

What might be the benefits and drawbacks of this approach? In this case, even though the wrongful act that led to the plaintiff's injury (the failure to inspect the train coupling) occurred in Alabama, the injury done to the plaintiff occurred fortuitously in Mississippi, where the train decoupled. Consequently, under the First Restatement approach, Mississippi’s fellow-servant law was applied. Does this approach adequately protect parties’ interests or the interests that other states may have?