/PLAYS uhv MOST sig-NIF-uh-kuhnt ri-LAY-shuhn-ship/·doctrine
Also known as:places of most significant relationship · most significant relationship
Written by attorneys · grounded in primary & secondary sources — see below
A choice-of-law principle under which a court applies the law or local law of the state that has the most significant relationship to the particular issue, the thing, and the parties. The principle requires evaluation of contacts according to their relative importance with respect to the issue, including the policies of interested states, the justified expectations of the parties, and the needs of judicial administration.
Sources & Authorities
How it applies
Common Examples
5
Trailers Titled in One State Garaged in Another
Praxis Leasing, a State K corporation, leased semi-trailers titled in State K to Horizon Freight, which stored and dispatched them from a hub in State L. State L creditors holding judgments against Horizon sought to levy on the trailers in State L court. The court weighed the titling contact in State K, the operational situs in State L, and the parties' expectations to identify the state with the most significant relationship to the trailers and the priority dispute.
Artwork Stored in Receivership State
Atlas Capital, a partnership in State A, held secured loans on artwork and precious metals stored in a State B vault operated by BullionSafe. After BullionSafe entered receivership in State B court, local creditors challenged Atlas's priority. The court evaluated the location of the collateral, the parties' contacts, and the policies of each state to select the law of the state with the most significant relationship to the priority issue.
Select any source to read its text and confirm it supports the definition.
Uniform Acts
Restatements
Casebooks
Out-of-State Accident Involving New York Guests
A New York host invited New York guests on a weekend trip that ended in an accident in Ontario. The guests sued the host in New York court for injuries. The court examined the parties' common New York domicile, the place of the relationship, and the policies underlying guest-host liability rules to determine that New York had the most significant relationship to the issue of liability.
Babcock v. Jackson12 N.Y.2d p. 482, 240 N.Y.S.2d p. 750, 191 N.E.2d p. 284
Foreign Injury Claim Against U.S. Officials
A Mexican citizen abducted in Mexico sued U.S. Drug Enforcement Administration agents in federal court, alleging the abduction caused harm in Mexico. The court assessed whether the claim arose in a foreign country and whether any U.S. contacts created a most significant relationship that would displace the foreign-injury rule.
Sosa v. Alvarez-Machain542 U.S. 692 (2004)
Interspousal Tort Claim After Out-of-State Accident
An Oklahoma couple was involved in a car accident in Missouri. The wife sued her husband in Oklahoma court for injuries. The court applied the most significant relationship test rather than the place-of-the-wrong rule, weighing the parties' Oklahoma domicile and the policies of both states to decide which law governed the interspousal immunity issue.
White v. White618 P.2d 921 (Okla.1980)
Common questions
Frequently Asked
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How does the place of most significant relationship test apply to interests in movables versus immovables?+
For immovables the reference is ordinarily to the law of the situs state, including its choice-of-law rules. For movables the reference is more often to the local law of the state with the most significant relationship to the thing and the parties on the particular issue.
Supporting sources
What factors does a court weigh when identifying the state of most significant relationship?+
A court evaluates the policies of interested states, the justified expectations of the parties, the basic policies underlying the field of law, the needs of judicial administration, and the relative importance of each contact with respect to the particular issue.
Supporting sources
When contacts lie in two states that have identical local rules on the issue, how does the test operate?+
The case is treated for choice-of-law purposes as if the contacts were grouped in a single state, so the court applies the common local rule without further selection.
Supporting sources
Does the test require a court to reach the same result a court of the selected state would reach?+
When the reference is to the law of the selected state, the forum aims to reach the same result a court of that state would reach on the actual facts. When the reference is only to local law, the forum applies the substantive rule without incorporating the selected state's choice-of-law rules.
Supporting sources
12 N.Y.2d p. 482, 240 N.Y.S.2d p. 750, 191 N.E.2d p. 284Conflict of Laws
…of Laws Restatement in the field of torts. According to the principles there set out, "The local law of the state which has the most significant relationship with the occurrence and with the parties determines their rights and liabilities in tort" (Restatement, Second, Conflict of Laws, § 379[1]; also Introductory Note to Topic 1 of Chapter 9,…