BETTS v. TOYOTA MOTOR CORPORATION (2026)

¶1 Appellants Wayne and Kristin Betts (collectively “Betts”) appeal a summary judgment in favor of Appellees Toyota Motor Corporation, Toyota Motor North America, Inc., and Toyota Motor Sales, U.S.A., Inc. (collectively “Toyota”). The Betts brought a products liability claim against Toyota after Wayne Betts (“Husband”) was injured in a single vehicle, rollover car accident while driving a 2002 Toyota Sequoia. The issue before this Court is whether Texas's statute of repose for products liability claims bars the Betts’ claim. We answer this question in the affirmative, as Texas has the most significant relationship to the parties regarding the statute of repose's applicability in this products liability case.

FACTS AND PROCEDURAL HISTORY

¶2 Toyota designed the 2002 Sequoia in Japan and manufactured the vehicle in Indiana. On January 10, 2002, Toyota first sold the vehicle in Georgia. In 2015, the vehicle was resold to Husband's grandmother in Texas. After her passing in 2016, Husband retitled the vehicle in his name.

¶3 At the time of the accident, the Betts resided in Arlington, Texas.  ¹ Husband had been a lifelong resident of Texas, while Kristin Betts (“Wife”) had been a resident since at least 2008. Husband held a commercial driver's license issued in Texas, which displayed his Texas address. The subject vehicle was registered, titled, tagged, and garaged in Texas.

¶4 The Betts asserted that they spent considerable time driving the vehicle in Oklahoma. For less than a year leading up to the accident, Husband worked as a frac hand and driver for Eco-Stim Energy Solutions, Inc. He traveled to Fairview, Oklahoma every two to four weeks for work, which required him to drive the subject vehicle and obtain a few oil changes while in Oklahoma.

¶5 On February 20, 2018, Husband picked up his brother-in-law around 2:30 a.m. and drove to Oklahoma to attend a work safety meeting. While driving in Fairview, Oklahoma, the vehicle lost traction due to icy road conditions. The Betts allege that, despite the vehicle clearly losing directional control, the electronic stability control failed to activate properly and did not correct the vehicle's path. As a result of the accident, Husband sustained injuries that left him paralyzed.

¶6 After the accident, Husband received medical care in Oklahoma for approximately one week. He then transferred to Baylor University Medical Center in Texas, where he received treatment for over two and a half months.

¶7 The Betts filed a products liability action against Toyota, alleging that the subject vehicle was defective. Toyota moved for summary judgment, arguing that Texas's 15-year statute of repose barred the Betts’ claim. Toyota asserted that Texas law should apply because Texas had the most significant contacts to the parties and the accident. In response, the Betts argued that Oklahoma law should apply since Husband frequently traveled to Oklahoma for work and his injury occurred there. Relying on the most significant relationship test adopted by this Court in Brickner v. Gooden, 1974 OK 91, ¶ 23, 525 P.2d 632, 637, the district court granted judgment in favor of Toyota, holding that Texas had the most significant relationship to the occurrence and the parties. As a result, the district court applied Texas's statute of repose, barring the Betts’ claims.

¶8 The Court of Civil Appeals (“COCA”) reversed the district court's judgment. COCA applied both Brickner v. Gooden, which relied on § 145 of the Restatement (Second) of Conflict of Law, and Edwards v. McKee, 2003 OK CIV APP 59, 76 P.3d 73, which relied on § 146 of the Restatement (Second) of Conflict of Law. COCA concluded that Texas did not have a more significant relationship with respect to any particular issue and instead applied Oklahoma law. This Court granted certiorari.

STANDARD OF REVIEW

¶9 Summary judgment resolves issues of law, and we review a district court's grant of summary judgment de novo. U.S. Bank, N.A. ex rel. Credit Suisse First Boston Heat 2005--4 v. Alexander, 2012 OK 43, ¶ 13, 280 P.3d 936, 939. Using the de novo standard, we subject the record to a new and independent examination without regard to the district court's reasoning or result. Gladstone v. Bartlesville Indep. Sch. Dist. No. 30, 2003 OK 30, ¶ 5, 66 P.3d 442, 446. All inferences and conclusions are to be drawn from the underlying facts contained in the record and are to be considered in the light most favorable to the party opposing the summary judgment. U.S. Bank, 2012 OK 43, ¶ 13, 280 P.3d at 939. If reasonable individuals could reach different factual conclusions under the evidentiary materials, summary judgment is improper. Id.

DISCUSSION

¶10 This products liability case involves a 2002 Toyota Sequoia that the Betts contend was defective. Toyota argues that Texas's statute of repose should apply, barring the Betts’ claim. Texas law requires a claimant to “commence a products liability action against a manufacturer or seller of a product before the end of 15 years after the date of the sale of the product by the defendant.” Tex. Civ. Prac. & Rem. § 16.012(b) (West 2025). Conversely, the Betts argue that the Court should apply Oklahoma law, which does not impose a statute of repose for products liability actions.  ² The primary question we need to resolve is whether Texas or Oklahoma law applies to this issue.

¶11 In Brickner v. Gooden, we adopted the Restatement's “most significant relationship” test for tort cases when there is a conflict of law. The plaintiffs in Brickner sought to recover for personal injuries resulting from an airplane crash that occurred in Mexico. 1974 OK 91, ¶ 1, 525 P.2d at 634. The issue before the Court was whether the parties’ rights and liabilities should be determined by the laws of Mexico or those of Oklahoma. The airplane operator argued that the law of the place of the injury should apply. However, the injured parties contended that the place having the most significant relationship with the occurrence and parties should apply. Id. ¶¶ 5-6, 525 P.2d at 634.

¶12 The Brickner Court expressly abandoned the lex loci delicti rule (which dictates that the law of the place of the wrong should apply) and held that the rights and liabilities of parties with respect to a specific tort issue shall be determined by the local law of the state with the most significant relationship to the occurrence and the parties. Id. ¶ 23, 525 P.2d at 637. It further adopted Restatement (Second) of Conflict of Law § 145, which outlines the factors to be evaluated based on their relative importance concerning the particular tort issue:

(1) the place where the injury occurred,

(2) the place where the conduct causing the injury occurred,

(3) the domicile, residence, nationality, place of incorporation and place of business of the parties, and

(4) the place where the relationship, if any, between the parties occurred.

Id. (citing Restatement (Second) of Conflict of Law § 145 (1971)).  ³ In reaching that conclusion, the Court cited with approval to several cases that clarified how to apply the most significant relationship test.

¶13 The Brickner Court examined Emery v. Emery, 45 Cal.2d 421, 289 P.2d 218, 222-23 (1955), wherein the California Supreme Court considered an action by minors against their father for personal injuries sustained in an automobile accident in Idaho. The parties were all residents of California. The court held that Idaho law would control and determine whether the defendant father would be liable for his conduct in driving the automobile. However, in determining the minors’ ability to sue and the father's immunity from suit due to their family relationship, the law of the family domicile (California) would be applied. The court emphasized that it is undesirable that the rights, duties, disabilities, and immunities conferred or imposed by the family relationship should constantly change as family members cross state lines during temporary absences from home. Id.

¶14 The Brickner Court also discussed Schwartz v. Schwartz, 103 Ariz. 562, 447 P.2d 254, 257-58 (1982), wherein a wife brought an action against her husband for injuries sustained in an automobile accident in Arizona. They were residents of New York and were in Arizona for a brief vacation at the time of the accident. The Arizona Supreme Court held that Arizona law would govern the issue of the husband's negligence. However, the wife's capacity to sue her husband in tort would be determined by the laws of New York, the domicile of the parties. Id.

¶15 Relying on these cases, the Brickner Court concluded that Oklahoma had the most significant relationship to the occurrence and parties. All the parties were residents of Oklahoma; the aircraft was hangered and registered in Oklahoma; and the trip both began and ended in Oklahoma. While the Court acknowledged that Mexico had an interest in the actions of the parties while they were within its borders and that the accident took place in Mexico, those aspects were not sufficient to alter the conclusion. The Court emphasized that “it would seem rather undesirable that the rights and obligations of the parties should be subject to change as the aircraft crossed the boundary lines of each jurisdiction.” Brickner, 1974 OK 91, ¶ 26, 525 P.2d at 638.

¶16 Similarly, in Hightower v. Kansas City Southern Railway Co., 2003 OK 45, ¶ 2, 70 P.3d 835, 838, the Court applied the most significant relationship test to a collision between a motor vehicle and train that occurred in Arkansas. Notably, all the parties were residents of Oklahoma. The plaintiff was returning home from a shopping trip that started and ended in Oklahoma. The railroad company was incorporated in a state other than Oklahoma or Arkansas, but the train was stationed in Oklahoma. At the time of the collision, the train was on a trip that began in Oklahoma and was scheduled to return there. We held that pursuant to the rule in Brickner, the laws of Oklahoma had the most significant relationship to the occurrence and parties based on these facts. Id. ¶ 15, 70 P.3d at 843.

¶17 The Brickner case, along with the cases discussed within it and subsequent related cases, are instructive here. These cases demonstrate that the law of one state (normally the state of the domicile of the parties) can apply to such issues as immunities, capacities to sue, rights, and duties of the parties in a case, without foreclosing that another state's law might be more suitable for another issue, like negligence in the operation of a vehicle. In this case, we must narrowly decide whether Texas's statute of repose for products liability claims applies to the subject vehicle; in other words, whether the Betts have the right to bring a claim, not whether the subject vehicle was defective at the time of the accident. We now apply the Brickner analysis to the facts at hand.

1. The Place where the Injury Occurred.

¶18 The first factor considers the place of injury, which occurred in Oklahoma. The Betts appear to argue that this factor is the most significant. However, this Court has rejected that position. Brickner, 1974 OK 91, ¶ 22, 525 P.2d at 637. Toyota argues that since this is a products liability case, the fact that the accident occurred in Oklahoma is coincidental and is not decisive in the conflict of law analysis. We agree with Toyota. While the location of the injury can indeed play an important role, it can also be coincidental or, for various reasons, bear little relation to the occurrence and parties concerning a specific issue. Restatement (Second) of Conflict of Law § 145, cmt. e (1971).

¶19 The focus here is on the product itself--specifically, when and where it was manufactured, sold, and used. These factors are important in determining whether a products liability statute of repose applies, not the location of the injury. For instance, the crux of a products liability claim is that the product alleged to have caused the injury was defective when it left the control of the manufacturer or retailer. Kirkland v. Gen. Motors Corp., 1974 OK 52, ¶¶ 29-30, 521 P.2d 1353, 1363. Further, a statute of repose looks to the specific time period within which a legal action must be initiated, starting from a particular event. Reynolds v. Porter, 1988 OK 88, ¶ 6, 760 P.2d 816, 819-20. In this context, the relevant event is the date of the initial sale of the product by Toyota. See Tex. Civ. Prac. & Rem. § 16.012(b) (West 2025).

¶20 The subject vehicle was placed into the stream of commerce in Georgia over 16 years ago and was subsequently resold in Texas. It was titled, registered, and garaged in Texas, and the owner was a Texas resident. Since the Betts primarily used the vehicle in Texas, it would typically be subject to Texas's statute of repose, except for the fact that it crossed state lines into Oklahoma at the time of the accident. As in Brickner, the rights and obligations of the parties should remain consistent, regardless of the vehicle crossing jurisdictional boundaries. Although Husband's injuries occurred in Oklahoma, the location of the accident was incidental given the circumstances of the case.

2. The Place where the Conduct Causing the Injury Occurred.

¶21 The second factor looks at the place where the conduct that caused the injury took place. In a products liability action, the relevant conduct occurs in the place where the defendant designed, manufactured, or first sold the product. See Kirkland, 1974 OK 52, ¶ 30, 521 P.2d at 1363 (holding a plaintiff must prove that the defect existed in the product at the time the product left the possession and control of the manufacturer or seller). In this case, the locations relevant to the conduct that led to the injury include Japan, where Toyota designed the vehicle; Indiana, where Toyota manufactured the vehicle; and Georgia, where the vehicle entered the stream of commerce. Thus, the second factor has no bearing on the analysis at hand because the laws of Japan, Indiana, and Georgia are not at issue in this case.

3. The Domicile, Residence, Nationality, Place of Incorporation, and Place of Business of the Parties.

¶22 The third factor considers the domicile, residence, nationality, place of incorporation, and place of business of the parties involved. For tort cases, the importance of these contacts depends largely upon the extent to which they are grouped with other contacts. Restatement (Second) of Conflict of Law § 145, cmt. e (1971). The circumstances under which a driver can claim damages because of another's negligence may be determined by the local law of their common domicile, especially if that domicile is the state from which they departed and to which they intended to return. Id. § 145, cmt. d. The domicile of the parties may also be the state of the applicable law when the conduct and injury occurred in a place that is fortuitous and bears little relation to the occurrence and the parties involved. Id.

¶23 The Betts argue that this factor weighs in favor of Oklahoma since Husband worked in Oklahoma sometimes for weeks at a time and drove his car in Oklahoma. We disagree. As in Highwater and Brickner, this factor looks to the domicile from which Husband departed and to which he intended to return. Highwater, 2003 OK 45, ¶ 15, 70 P.3d at 843; Brickner, 1974 OK 91, ¶ 26, 525 P.2d at 638. When Husband traveled to Oklahoma for work, he always returned to Texas. Even after the accident, Husband returned to Texas and received much of his medical care in Texas. While he had been traveling to Oklahoma for work, his job could have changed at any time. Husband was a lifelong resident of Texas and, at the time of the accident, held a Texas driver's license with a Texas address.

¶24 Moreover, the place of incorporation and business of Toyota is disputed.  ⁴ However, the parties provided no evidence to suggest that Toyota was incorporated or headquartered in Oklahoma. Therefore, the contacts of the parties, notably the Betts, are primarily linked to Texas, indicating that this factor weighs in favor of Texas.

4. The Place where the Relationship, if any, Between the Parties Occurred.

¶25 The fourth factor to consider is the place where the relationship between the parties is centered. If the injury stems from an action that occurred during the course of the relationship between the plaintiff and the defendant, the location of that relationship becomes an important aspect. Restatement (Second) of Conflict of Law § 145 cmt. e (1971). Here, when Husband's grandmother gave him the subject vehicle and he registered it in his name in Texas, any relationship he had with Toyota was centered in Texas. He owned and primarily used the vehicle in Texas. Thus, the fourth factor weighs slightly in favor of Texas.

5. General Conflict of Law Considerations.

¶26 The final factor to consider is the general concerns that arise in any conflict of law case.  ⁵ We should seek harmonious relations between states and to facilitate commercial intercourse between them. Restatement (Second) of Conflict of Laws § 6(2)(a) (1971). We also need to consider the basic principles underlying the particular field of tort law. Id. § 6(2)(b)-(c), (e).

¶27 Texas has an interest in overseeing products sold and used in Texas. As a result, it enacted a products liability statute of repose to provide absolute protection to certain parties from the burden of indefinite potential liability. See Galbraith Eng'g. Consultants, Inc. v. Pochucha, 290 S.W.3d 863, 866 (Tex. 2009). At the same time, Oklahoma has an interest in the safety of its roadways. See Brickner, 1974 OK 91 ¶ 26, 525 P.2d at 638 (discussing Mexico's interest in an accident that occurs within its borders). Thus, applying Texas's statute of repose to tort claims that arose in Oklahoma could undermine Oklahoma's interest in the safe design of vehicles operating on its roads. However, this interest is diminished as to vehicles incidentally driving in Oklahoma as opposed to vehicles garaged here. Further, Oklahoma has minimal interest in applying its own substantive law (in this case, the lack of a statute of repose) for the benefit of non-resident plaintiffs suing non-resident defendants.

¶28 Another factor to consider is the protection of justified expectations by all parties. See Restatement (Second) of Conflict of Laws § 6(2)(f)-(g) (1971). With respect to any expectations in the protection of Oklahoma law, the Betts were Texas residents that initiated contact with Oklahoma when Husband drove into the state. The subject vehicle was not purchased or registered in Oklahoma. Instead, the Betts purchased, titled, and registered the vehicle in Texas. In addition, Toyota would have had a reasonable expectation that Texas law would govern a Texas vehicle that had work-related connections in Oklahoma.

¶29 We must also examine the certainty, predictability, uniformity of result, and the ease in the determination and application of the law to be applied. See Restatement (Second) of Conflict of Laws § 6(2)9(f)-(g) (1971). Under the circumstances of this case, applying Texas law would more likely foster predictability and uniformity. And it makes conflict of law determinations less complicated to hold that the state where a vehicle is registered and garaged should ordinarily supply the governing statute of repose, if any, for products liability claims concerning that vehicle.

CONCLUSION

¶30 Considering all the factors in Restatement (Second) of Conflict of Law § 145, we conclude that Texas has the more significant relationship to the parties as to the statute of repose's applicability in this products liability case. Consequently, Texas's statute of repose for products liability claims applies, and the Betts’ claims are barred. We vacate COCA's opinion and affirm the district court's judgment.

COURT OF CIVIL APPEALS’ OPINION VACATED; DISTRICT COURT'S JUDGMENT AFFIRMED.

FOOTNOTES

1.   The Betts currently reside in Arizona. They moved to Arizona to seek additional medical care for Husband.

2.   In the district court and on appeal, the Betts argue that Oklahoma's borrowing statute, 12 O.S.2021, § 105, governs this case. The borrowing statute states that the period of limitation for a claim arising outside of Oklahoma shall be determined by the law of the place where the claim accrued or by Oklahoma law, whichever last bars the claim. The Betts contend that, under the rule, Oklahoma law would apply to this case. However, we have previously established that the borrowing statute is procedural law, while a statute of repose is substantive law. Consol. Grain & Barge Co. v. Structural Sys., Inc., 2009 OK 14, ¶¶ 8-10, 212 P.3d 1168, 1171-72. The application of Texas's statute of repose to this case is a substantive law question, affecting the rights and liabilities of the parties involved. Therefore, we must apply the most significant relationship test to determine what law applies. Even more, the borrowing statute does not apply in this case because all parties agree that the Betts’ claim accrued in Oklahoma.

3.   In reaching its decision in this case, COCA applied Edwards v. McKee, 2003 OK CIV APP 59, 76 P.3d 73, which relied on § 146 of the Restatement (Second) of Conflict of Law. Section 146 is specific to personal injuries and emphasizes that the place of the injury is the default choice of law. In Brickner, we adopted § 145 that applies to all torts and all issues in tort. The Court rejected the lex loci delicti rule (the law of the place of the wrong), while it simultaneously adopted § 145, affirming that it would consider all the relevant factors. In subsequent cases, we continued to take all factors into account. Our Court has never adopted the more specific § 146 relating only to personal injuries, nor do we do so today.

4.   Toyota stated in its reply brief to its motion for summary judgment that the Toyota companies are headquartered and have their principal place of business in Plano, Texas. However, this information was not included in Toyota's initial motion for summary judgment.

5.   Section 145 states that the rights and liabilities of the parties with respect to an issue in tort are determined by the local law of the state which, with respect to that issue, has the most significant relationship to the occurrence and the parties, based on the principles stated in § 6. Restatement (Second) of Conflict of Laws § 145 (1971).Section 6 factors relevant to the choice of the applicable rule of law include:the needs of the interstate and international systems,(b) the relevant policies of the forum,(c) the relevant policies of other interested states and the relative interests of those states in the determination of the particular issue,(d) the protection of justified expectations,(e) the basic policies underlying the particular field of law,(f) certainty, predictability, and uniformity of result, and(g) ease in the determination and application of the law to be applied.Restatement (Second) of Conflict of Laws § 6 (1971).

Winchester, J.

CONCUR: ROWE, C.J., KUEHN, V.C.J., WINCHESTER, EDMONDSON, GURICH, DARBY, KANE AND JETT, JJ. DISSENT: COMBS, J.