Also known as: laws of the place · lex loci
Written by attorneys · grounded in primary & secondary sources — see below
The local law of the jurisdiction where a key event such as an injury, contract performance, or will execution occurred. This body of rules supplies the substantive standards for liability, validity, or recovery when choice-of-law principles point to the place of the event rather than the forum or another connected jurisdiction.
Lance Lee, while maintaining an apartment in Switzerland during an extended work stay, signed his will before a Swiss notary. After moving to State B and dying there, his heirs challenged the document under State B's stricter witness rules. The court applied the law of the place of execution and upheld the will because Swiss formalities were satisfied at the time of signing.
Lena Lawson was injured in a car accident while visiting Missouri with her husband Logan Lane. She later sued him in Oklahoma, their home state, which permitted interspousal tort actions. The court looked to the law of the place where the tort occurred and dismissed the claim because Missouri law barred such suits between spouses.
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Liam Larson, a Delaware corporation officer, breached a contract that fixed New York as the place of performance. When the non-breaching party sued in Delaware federal court, the court applied the law of the place of performance to measure damages and interest rather than creating an independent federal rule.
Laura Lewis suffered injury from a federal employee's negligent act that occurred in Mexico. She filed suit under the Federal Tort Claims Act in a U.S. district court. The court applied the law of the place where the act or omission occurred to determine whether the United States would be liable if it were a private person.
Luna Lang, a Pennsylvania resident, sued a New York defendant in federal court in Pennsylvania for injuries sustained in that state. The defendant urged the court to fashion a uniform federal common-law rule on liability. The court instead applied Pennsylvania substantive law, including its conflict-of-laws rules, to decide the claim.
Lexicon Media contracted with a federally chartered bank whose operations spanned multiple states. When a dispute arose over performance obligations, the bank argued for a uniform national rule. The court applied the law of the place where the relevant acts occurred to measure the bank's liability as if it were a private party.
Yes. Under Uniform Probate Code section 2-506 a written will is valid if its execution complies with the law of the place where the will is executed or the law of the place where the testator is domiciled or has a place of abode at execution or death.
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The Act makes the United States liable for torts of its employees under circumstances where a private person would be liable in accordance with the law of the place where the act or omission occurred.
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Yes. Erie and Klaxon require federal courts sitting in diversity to apply the substantive law of the state in which they sit, including that state's conflict-of-laws rules that often point to the law of the place of injury or performance.
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Yes. Restatement (Second) of Conflict of Laws section 207 provides that the measure of recovery for breach of contract is determined by the local law of the state selected by application of the rules of sections 187-188, frequently the place of performance.
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…that § 34 "has been uniformly held to be no more than a declaration of what the law would have been without it: to wit, that the lex loci must be the governing rule of private right, under whatever jurisdiction private right comes to be examined." See also Bank of Hamilton v. Dudley's Lessee , 2 Pet. 492, 525. Compare…