Jepson v. Gen. Cas. Co. - 513 N.W.2d 467 (Minn. 1994)

Rule:

The five choice influencing factors for choice of law analysis are: (1) predictability of result; (2) maintenance of interstate and international order; (3) simplification of the judicial task; (4) advancement of the forum's governmental interest; and (5) application of the better rule of law.

Facts:

Respondent filed a declaratory judgment action in Minnesota to determine whether he was entitled to Minnesota underinsured motorist (UIM) benefits as a result of an auto accident. The policy was purchased in Minnesota for a business located in North Dakota. The policy covered seven vehicles. The accident occurred in Arizona. The trial court concluded that respondent was entitled to Minnesota (UIM) benefits based on its determination that Minnesota, and not North Dakota, law applied to the anti-stacking provisions in the policy. The trial court also concluded, and the court of appeals affirmed, that under Minnesota law respondent could stack the benefits on each of the seven vehicles insured under the policy. At the time of the accident, North Dakota law would enforce the anti-stacking provisions in the policy while Minnesota law would not. The insurance company sought review of the lower courts’ decision. 

Issue:

Did Minnesota law apply to the anti-stacking provisions in the insurance policy in question? 

Answer:

No.

Conclusion:

The court noted that in analyzing a choice of law issue, the first consideration is whether the choice of one state's law over another's creates an actual conflict. In this case, North Dakota would enforce the anti-stacking provision in the policy, while under the law in effect at the time of the accident Minnesota would not. Thus, an actual conflict existed. Next, the court held that both Minnesota and North Dakota have sufficient contacts such that the law of either state could be constitutionally applied. Having concluded that there was a conflict between Minnesota and North Dakota law and that either may be constitutionally applied, the court then considered the five choice influencing factors set out in Milkovich v. Saari, 295 Minn. 155, 203 N.W.2d 408 (1973). An analysis of the choice of law factors resulted in the court applying North Dakota rather than Minnesota law; thus, the court reversed the judgment of the lower courts.