Under New York's choice of law rules, the IAS Court correctly determined that New Jersey law is applicable to these personal injury actions by New Jersey domiciliaries and bars all claims against GMAC ( see, Schultz v Boy Scouts, 65 N.Y.2d 189; Haggerty v Cedeno, 279 N.J. Super. 607, 609, 653 A.2d 1166, 1167-1168, cert denied 141 N.J. 98, 660 A.2d 1197). New York's and New Jersey's conflicting rules relate to allocating losses that result from admittedly tortious conduct. Accordingly, New York has only a minimal interest in determining the extent of the remedy in these actions by foreign domiciliaries. Although plaintiffs have presented compelling evidence that GMAC is a New York domiciliary, it is clear that New Jersey has the most significant relationship with this case since GMAC leased, registered and insured the car in that State.
Concur — Sullivan, J.P., Ellerin, Wallach and Asch, JJ.