Hague v. Allstate Ins. Co. - 289 N.W.2d 43 (Minn. 1979)

Rule:

Where a plaintiff is a resident of the State of Minnesota and decedent's estate is probated in Minnesota, defendant does business in the state and was properly served with process, the Minnesota court has jurisdiction of the case. Also, when an insurance company doing business in a number of states writes a policy on an automobile, the company knows the automobile is a movable item, which will be driven from state to state. The company, therefore, accepts the risk that the insured may be subject to liability not only in the state where the policy is written, but also in states other than where the policy is written, and that in many instances those states will apply their own law to the situation. Such a contract is not like the usual commercial transaction where the law of the state where the contract is made should and does play a more important role.

Facts:

Appellant insurer Allstate Insurance Company filed a motion for rehearing after the case relating to the claims of respondent Lavinia Hague, the personal representative of a decedent's estate, had been originally decided by the court. The petition was granted, and the case was reheard en banc. The appellant had challenged the court's jurisdiction and the court's determination that Minnesota law had been properly applied.

Issue:

Did the decision require reversal?

Answer:

No.

Conclusion:

The court, upon rehearing, held that because there was no manifest error of fact, the case was fully argued, and no new issues of fact or of law had been presented, there was no reason justifying a reversal. The court explained its earlier decision by opining that the questions of jurisdiction and conflict of laws had to be separated. The court thought that there was no real question of jurisdiction. Where the respondent was a resident of the state and the decedent's estate was probated in Minnesota, the appellant did business in the state, and was properly served with process, thus, the Minnesota court had jurisdiction of the case. Additionally, Minnesota law was properly applied on the question of "stacking" insurance coverage. As the appellant accepted the risk that an insured was possibly subject to liability not only in the state where the automobile insurance policy was written, but also in other states because it was aware that an automobile was a movable item. The court concluded that the application of Minnesota law was not so arbitrary and unreasonable as to violate due process.