Torts. In an action brought in one state for injuries done in another, the statutes and decisions of the courts of the latter state must fix the liability; Njus v. Ry. Co., 47 Minn. 92, 49 N. W. 527 ; Erickson v. S. S. Co., 96 Fed. 80 ; Burnett v. R. Co., 176 Pa. 45, 34 Atl. 972 (where a ticket was purchased at a point in New Jersey to a place in New York ; the person was injured in Penusylz vania ; the law of Pennsylvania was held to apply) ; Alexander v. Pennsylvania Co., 48 Ohio St. 623, 30 N. E. 69 ; Railway Co. v. Lewis, 89 Tenn. 235, 14 S. W. 603. See Le high Valley R. Co. v. Pennsylvania, 145 U. S. 193, 12 Sup. Ct. 806, 36 L. Ed. 672.
In a proceeding to limit liability for claims against a French vessel found to be in fault for a collision in a fog on the high seas, the law of France, which authorizes a recovery for loss of life against the vessel in fault, will be enforced by the courts of the United States, although the French courts, in ap plying the facts, found the international rule as to the speed of vessels in a fog might not have held such vessel to be at fault; La Bourgogne, 210 U. S. 95, 28 Sup. Ct. 664, 52 L. Ed. 973.
Movables in general. An assignment of a movable which gives a good title according to the law of the country where it is situat ed is recognized as valid in England, what ever the domicil of the parties may be; [1892] 1 Ch. 238; so it lies with the law of
the place where a written instrument is sit uated to determine whether it is negotiable or not ; [1905] 1 K. B. 677. Where, by the law of the place where goods are shipped and where the ship is, a shipper is entitled to ex ercise a right of stoppage in transitu, and has exercised that right in a manner recog nized as valid by such law, his title to the goods will be recognized ; 1 East 515. The rights of the assignor and the assignee on an assignment, in one country, of a document of title to a debt or to an interest in per sonal property, are in general governed by the law of the country where the assignment takes place, although the debt may be due from persons living in, or the personal prop erty may be situated in, a foreign country; [1898] A. C. 616. The validity of an assign ment of documents, such as policies of insur ance ; 17 Q. B. D. 309 ; or negotiable instru ments ; [1904] 2 K. B. 870 ; is determined by the law of the place where the assignment is made ; 15 App. Cas. 267.