Where the parties’ contract for health-care-plan administration provided that Iowa law would control issues of contract interpretation and validity, the provision did not mean that all contract-related tort claims would be governed by Iowa law. Under Virginia’s choice-of-law rules, tort claims apart from issues of contract interpretation and validity are governed by the law of the “place of the wrong.”
Here, the place of the alleged wrong was Virginia. Virginia doesn’t permit tort claims arising solely out of breached contractual duties, some some counterclaims are dismissed.
Plaintiff’s motion for judgment on the pleadings granted in part and denied in part.