Law School Case Brief
Allstate Ins. Co. v. Hague - 449 U.S. 302, 101 S. Ct. 633 (1981)
In deciding constitutional choice-of-law questions, whether under the Due Process Clause, U.S. Const. amend. XIV, or the Full Faith and Credit Clause, U.S. Const. art. IV, § 1, the Supreme Court of the United States has traditionally examined the contacts of the state, whose law was applied, with the parties and with the occurrence or transaction giving rise to the litigation. In order to ensure that the choice of law is neither arbitrary nor fundamentally unfair, the Court has invalidated the choice of law of a state which has had no significant contact or significant aggregation of contacts, creating state interests, with the parties and the occurrence or transaction.
The decedent, Ralph Hague, died of injuries suffered when a motorcycle on which he was a passenger was struck by an automobile. The accident occurred in Wisconsin near the Minnesota border. The operators of both vehicles were Wisconsin residents, as was decedent, who, however, had been employed in Minnesota and had commuted daily to work from Wisconsin. Neither vehicle operator carried valid insurance, but the decedent held a policy issued by petitioner Allstate Insurance Co. ("Allstate") covering three automobiles owned by him. The policy contained an uninsured motorist clause insuring him against loss incurred from accidents with uninsured motorists, but limiting such coverage to $15,000 for each automobile. After the accident, decedent's widow, respondent Lavinia Hague, moved to and became a resident of Minnesota, and was subsequently appointed in that state as personal representative of the decedent's estate. She then filed a lawsuit in Minnesota state court seeking a declaration under Minnesota law that the $15,000 uninsured motorist coverage on each of the decedent's automobiles could be "stacked" to provide total coverage of $45,000. Allstate defended on the ground that whether the three uninsured motorist coverages could be stacked should be determined by Wisconsin law, since the insurance policy was delivered in Wisconsin, the accident occurred there, and all persons involved were Wisconsin residents at the time of the accident. The trial court, interpreting Wisconsin law to disallow stacking, concluded that Minnesota's choice-of-law rules required the application of Minnesota law permitting stacking, and granted summary judgment for Mrs. Hague. The Supreme Court of Minnesota affirmed. Allstate was granted a writ of certiorari.
Did Minnesota's choice of its own substantive law violate the Due Process Clause, U.S. Const. amend. XIV or the Full Faith and Credit Clause, U.S. Const. art. IV, § 1?
The Supreme Court of the United States affirmed the state supreme court's judgment. The Court found that Minnesota's choice of its own substantive law did not violate the Due Process Clause, U.S. Const. amend. XIV, or the Full Faith and Credit Clause, U.S. Const. art. IV, § 1. Minnesota's contacts with the parties and occurrences—including the fact that decedent worked in Minnesota for 15 years, Allstate conducted business there, and Mrs. Hague became a Minnesota resident with no evidence she moved there in anticipation of litigation—were significant enough to warrant Minnesota choosing to apply its own substantive.
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