"Under Illinois conflict-of-law principles, the substantive law of the State with the most significant contacts with the occurrence applies. [Citation.] Procedural issues are governed by Illinois law. [Citation.]" Macias v. Inland Steel Co. (1986), 147 Ill. App.3d 411, 414, 497 N.E.2d 1206. • 1 Inland argues its safety manuals established that Inland did not assume the legal obligation to inspect or maintain a safe condition at Three Star's worksite.
However, it is not improper argument for an attorney to suggest how a special interrogatory should be answered, as long as the jury is not admonished to conform its answer to its verdict. Burns v. Howell Tractor Equipment Co. (1977), 45 Ill. App.3d 838, 848, 360 N.E.2d 377, 385; Macias v. Inland Steel Co. (1986), 147 Ill. App.3d 411, 418, 497 N.E.2d 1206, 1211. Based upon the record before us, we find no error in counsel's argument to the jury.
Illinois applies the law of the state where the injury occurred for substantive issues and the law of the forum state for procedural issues. Humanes v. General Elec. Transp. Services, Inc., 2000 WL 1029127, at *2 (N.D. Ill. 2000), citing Macias v. Inland Steel Company, 147 Ill. App.3d 411 (1st Dist. 1986). Statute of limitation questions are procedural in Illinois. Id., citing Kalmich v. Bruno, 553 F.2d 549, 553 (7th Cir. 1977).
Illinois conflict-of-law principles require courts to apply the law of the state where the injury occurred for substantive issues and the law of the forum state for procedural issues. Macias v. Inland Steel Company, 147 Ill. App.3d 411 (1st Dist. 1986). Statute of limitation questions are procedural in Illinois.
In Sommese v. Maling Brothers Inc. (1966), 36 Ill.2d 263, this court held that it is improper for counsel to reveal the identity of the party that submitted a special interrogatory to the jury, and to inform them of the necessity of conforming the answer to the special interrogatory with their general verdict. It is proper, however, to argue to the jury that a special interrogatory should be answered in accordance with the evidence. ( Macias v. Inland Steel Co. (1986), 147 Ill. App.3d 411.) Here, the plaintiffs' counsel did not expressly state that the answers to the special interrogatory and the general verdict must be consistent. His argument that the jury should answer that the actions of the hospital were not the sole proximate cause of the injuries was not a statement that the jury should base its answer to the interrogatory on the evidence presented.
• 17, 18 The railroad next contends that the verdict for plaintiffs is excessive as a matter of law. An award of damages is not subject to scientific computation and thus it is a matter for a jury's determination. ( Macias v. Inland Steel Co. (1986), 147 Ill. App.3d 411, 497 N.E.2d 1206; Dooley v. Darling (1975), 26 Ill. App.3d 342, 324 N.E.2d 684.) Where the jury's verdict is not the result of prejudice, sympathy or passion, it will not be set aside.