449 U.S. 302, 101 S. Ct. 633, 66 L. Ed. 2d 521 (1981)
Ralph Hague, a Wisconsin resident who had been employed in Red Wing, Minnesota, for the fifteen years preceding his death, died of injuries suffered when a motorcycle on which he was a passenger was struck from behind by an automobile.1 The accident occurred in Pierce County, Wisconsin, immediately across the Minnesota border from Red Wing.2 The operators of both vehicles were Wisconsin residents, as was the decedent, who resided with respondent in Hager City, Wisconsin.3
Mr. Hague held a policy issued by petitioner Allstate Insurance Co. covering three automobiles owned by him.4 The policy contained an uninsured motorist clause insuring him against loss incurred from accidents with uninsured motorists.5 The uninsured motorist coverage was limited to $15,000 for each automobile.6
After the accident, respondent moved to Red Wing, Minnesota.7 She subsequently married a Minnesota resident and established residence with her new husband in Savage, Minnesota.8 At approximately the same time, a Minnesota Registrar of Probate appointed respondent personal representative of her deceased husband’s estate.9 Following her appointment, she brought this action in Minnesota District Court seeking a declaration under Minnesota law that the $15,000 uninsured motorist coverage on each of her late husband’s three automobiles could be stacked to provide total coverage of $45,000.10
Allstate defended on the ground that whether the three uninsured motorist coverages could be stacked should be determined by Wisconsin law.11 Allstate pointed out that the insurance policy was delivered in Wisconsin, the accident occurred in Wisconsin, and all persons involved were Wisconsin residents at the time of the accident.12 The Minnesota District Court interpreted Wisconsin law to disallow stacking.13 Nevertheless, the court concluded that Minnesota’s choice-of-law rules required the application of Minnesota law permitting stacking.14 The court refused to apply Wisconsin law as inimical to the public policy of Minnesota and granted summary judgment for respondent.15
The Minnesota Supreme Court, sitting en banc, affirmed the District Court.16 The court interpreted Wisconsin law to prohibit stacking and applied Minnesota law after analyzing the Minnesota contacts and interests within the analytical framework developed by Professor Leflar.17 The United States Supreme Court granted certiorari to determine whether the Due Process Clause of the Fourteenth Amendment or the Full Faith and Credit Clause bars the Minnesota Supreme Court’s choice of substantive Minnesota law.
Whether the Due Process Clause of the Fourteenth Amendment or the Full Faith and Credit Clause of Art. IV, § 1 bars the Minnesota Supreme Court’s choice of substantive Minnesota law?18
For a State’s substantive law to be selected in a constitutionally permissible manner, that State must have a significant contact or significant aggregation of contacts, creating state interests, such that choice of its law is neither arbitrary nor fundamentally unfair.19
No. Minnesota had three contacts with the parties and the occurrence giving rise to the litigation.20 First, Mr. Hague was a member of Minnesota’s work force, having been employed in Red Wing, Minnesota for the fifteen years preceding his death, and he commuted daily from Wisconsin to his place of employment.21 Second, Allstate was at all times present and doing business in Minnesota.22 Third, respondent became a Minnesota resident prior to institution of this litigation and was appointed personal representative of the estate by a Minnesota court.23
In the aggregate, these contacts permit selection by the Minnesota Supreme Court of Minnesota law allowing the stacking of Mr. Hague’s uninsured motorist coverages.24
The choice of Minnesota law by the Minnesota Supreme Court did not violate the Due Process Clause or the Full Faith and Credit Clause.25
Related opinions on this issue
Justice Stevens viewed this unusual case as requiring separate analysis of the Full Faith and Credit Clause and the Due Process Clause.26 He concluded that the Full Faith and Credit Clause does not require Minnesota to apply Wisconsin law because there is no threat to national unity or Wisconsin's sovereignty.27 The insurance policy provided coverage for accidents that might occur in other States.28
On the due process question, Justice Stevens found no fundamental unfairness in Minnesota's application of its stacking rule.29 Stacking was the rule in most States at the time the policy was issued.30 The policy provided nationwide coverage, so the parties could have anticipated application of other states' laws.31
Justice Powell accepted the basic principles set forth in the plurality opinion but found that Minnesota lacked sufficient contacts with the litigation to apply its stacking rule.32 The postaccident residence of the plaintiff-beneficiary is constitutionally irrelevant to the choice-of-law question.33 The insurer's doing business in the forum is not significant when it does business in all states.34
The insured's employment in Minnesota does not further any substantial state interest relating to employment in this compensation context.35