nial of GM’s and Chapman Auto’s motion to apply Arizona law.[7] Since this court’s 1996 decision in Motenko , Nevada has followed the “overwhelming interest” test for resolving choice-of-law issues in tort actions. The “overwhelming interest” test can best be described as a hybrid of principles contained in the First and Second Restatements of Conflict of Laws. While this “overwhelming interest” test was intended to create a seemingly bright-line approach to resolving choice-of-law issues, it did not deviate from prior tests in a way that furthered the elusive goals of uniformity and predictability in complex, multiparty tort actions, and it fails to take advantage of the ongoing legal scrutiny by other courts and commentators given to the Second Restatement. Therefore, we conclude that our choice-of-law jurisprudence in tort actions warrants review. Before Motenko, Nevada followed the vested rights approach Historically, Nevada followed the First Restatement’s vested rights approach when confronted with choice-of-law issues in tort actions.[8] This approach required the court to apply the “substantive law of the forum in which the injury occurred.”[9] Although the application of the vested rights approach proved predictable, this court later expressed concern with the test in Motenko .[10] In that case, this court abandoned the vested rights approach because that test blindly applied the substantive law of the forum where the injury occurred and produced “unjustifiably harsh results.”[11] The current state of the law under Motenko In Motenko , the plaintiff and his mother were Massachusetts residents.[12] While visiting Las Vegas, the mother fell and injured herself in a hotel.[13] The plaintiff then filed a claim for loss of parental consortium in a Nevada district court.[14] The district court applied the vested rights approach and determined that Nevada law applied because the injury occurred in Nevada.[15] This court agreed with the district court’s determination that Nevada law applied but did so after creating and applying the “overwhelming interest” test.[16] Although a majority opinion was not reached, the Motenko court created the new “overwhelming interest” test, which retained a key feature of the vested rights approach and borrowed principles from the Second Restatement’s “most significant relationship” test.[17] The Motenko test requires the trial court to apply the substantive law of the forum in tort cases unless “another state has an overwhelming interest.”[18] Another state has an overwhelming interest if two or more of the Motenko factors are met.[19] This approach reduces the conflict-of-law analysis in tort actions to a quantitative comparison of contacts, without any regard to a qualitative comparison of true conflicts-of-law between states. The Motenko test is a hybrid of the vested rights approach and the most significant relationship test Both the vested rights approach and the Motenko test start from the premise that the law of the forum governs the choice-of-law analysis in tort cases.[20] Thus, both approaches emphasize a predictable and identifiable starting point that helps to further uniformity and predictability. The Motenko test also borrowed and then modified some, but not all, of the Second Restatement’s most significant relationship test for torts.[21] The Second Restatement’s most significant relationship test for torts is comprised of two sections. First, section 145(1) states that the rights and liabilities of the parties in tort actions are determined by the local law of the state that “has the most significant relationship to the occurrence and the parties under the principles stated in § 6.” Second, section 145(2) lists four contacts to be considered when applying the section 6 principles.[22] Despite the clearly stated framework in section 145(1), the Motenko test ignores the qualitative principles in section 6, but utilizes the four quantitative contacts in section 145(2).[23] The Second Restatement’s four quantitative contacts in section 145(2) were designed to play a supporting role to the primary qualitative principles of section 6.[24] Thus, the Motenko test effectively reversed the clearly stated order of priority between section 6 and section 145(2) by making the section 145(2) contacts the primary inquiry. The test also ignored the application of other Restatement sections in choice-of-law determinations designed specifically for a particular tort claim. Thus, Motenko created a new, independent test that lacks the historical evaluation, and cannot benefit from ongoing legal scrutiny, to be realized from the First and Second Restatements. The Motenko test fails to further certainty, predictability, and uniformity The stated purpose of the Motenko test was to meet “the goal of a higher degree of certainty, predictability and uniformity of result.”[25] However, as this court’s decision in Northwest Pipe Co. v. District Court[26] demonstrates, the application of the Motenko test to multiparty tort actions hinders, rather than promotes, these goals. In Northwest Pipe , the defendant, an Oregon corporation, was sued for wrongful death in Nevada by family members of individuals who were killed in a California car accident. Two of the decedents were Nevada residents and four of the decedents were California residents. Nine of the eleven plaintiffs were Nevada residents with the remaining two residing in California.[27] The plurality and concurrence applied the Motenko overwhelming interest test and produced an outcome in which the Nevada plaintiffs’ claims proceeded under Nevada law and the California plaintiffs’ claims against the same defendant proceeded under California law.[28] Instead of qualitatively analyzing the contacts that each cause of action and party had with the competing states, the court simply counted the number of Motenko contacts each plaintiff had with California.[29] While this approach may seem simplistic enough to produce uniform and predictable results, it took a plurality and a concurrence, and a dissent to determine which state’s law applied to each cause of action. As demonstrated in Northwest Pipe , the Motenko test does not deviate from the vested rights approach in a way that furthers the goals of uniformity and predictability in complex, multiparty tort actions. Limiting an inquiry in a difficult area of law to simply counting contacts between the competing states and the parties ignores an essential part of the Second Restatement’s most significant relationship test—which state has the most significant relationship to the tort and the parties? This question can be answered most effectively through the qualitative analysis framework that the most significant relationship test provides. The Second Restatement’s most significant relationship test now governs tort actions in Nevada We take this opportunity to clarify Nevada’s choice-of-law jurisprudence and hold that the Second Restatement’s most significant relationship test governs choice-of-law issues in tort actions unless another, more specific section of the Second Restatement applies to the particular tort. Consequently, we overrule Motenko . While we are cognizant that choice-of-law analyses may, at times, lead to subjective results, the best approach to keeping those results uniform is to apply the law of the state that has the most significant relationship to the occurrence and the parties.[30] The Second Restatement’s most significant relationship test begins with a general principle, contained in section 145: the rights and liabilities of parties with respect to an issue in tort are governed by the local law of the state that, “with respect to that issue, has the most significant relationship to the occurrence and the parties under the principles stated in § 6.” Section 6 identifies the following principles: (1) A court,

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