Conflict of Laws

Question 1

Matters of procedure are governed by the forum’s ____ law:

Answer 1

SUPERB
S – SERVICE of process (SWAPS)
U – Issues of UNTIMELY claims (SOL), but where the claim arose outside of the state,
and the plaintiff is a non-domiciliary, then if that state has a “borrowing statute” it will borrow the SOL of the state where the cause of action arose, and if it’s shorter than the state where the claim is pending, then the plaintiff’s claim is barred
P – Rules of PLEADINGS
E – Rules of EVIDENCE
R – Provisional REMEDIES (LIARS) 
B – BURDENS of proof

Question 2

In tort cases, courts look at ____ to determine which state has the most significant interests.

Answer 2

GRID C
G – GOVERNMENT interest and the policy for its law;
R – The state, if any, where the parties RELATIONSHIP is centered;
I – The state where the INJURY occurred;
D – DOMICILES of the contracting parties
C – State where the CONDUCT causing the injury occurred.

Question 3

The court will look to ____ to resolve a conflict of laws in a contract case:

Answer 3

SPEND
S – The state where the SUBJECT matter of the contract is located
P – The state where the contract is to be PERFORMED
E – The state where the contract was EXECUTED (10 states use just this single factor.)
N – The state where the contract was NEGOTIATED
D – The DOMICILES of the contracting parties