Total Oilfield Services, Inc. v. Garcia
Jose Alejo Garcia, a Texas resident, was killed in an industrial accident in Oklahoma while working for Total Oilfield Services, a Texas corporation. His survivors received worker's compensation benefits under Oklahoma law and subsequently sued in Texas for exemplary damages under the Texas Wrongful Death Act. The trial court dismissed the action due to Oklahoma's exclusive remedy, but the court of appeals reversed, asserting the extra-territorial effect of the Texas Wrongful Death Act. This court refused the application for writ of error, finding no reversible error in the outcome. However, it disapproved the court of appeals' reasoning that the 'most significant relationship' rule was inapplicable, clarifying that said rule should be applied in such conflict of laws cases.