Michigan Choice of Law- Property, DE, Corp, Marriage

Question 1

MI Choice- Real Property

Answer 1

Vested Rights Rule

Question 2

MI Choice- Conveyance of Personal Property

Answer 2

Vested Rights: apply the law of place where property situated at time of transaction
2d Restatement- UCC contains provisions and governs choice of law, usually same result

Question 3

MI Choice- Decedents Estates Real Property

Answer 3

Vested Rights: where property located

2d Rest.- most significant relationship, usually leads back to vested rights

Question 4

MI Choice- Decedents Estates Personal Property

Answer 4

Vested Rights: Persons domicile at death

2d Rest.- most significant relationship

Question 5

MI Choice- Corporations Internal Affairs

Answer 5

Vested Rights: apply state of incorporation

2d Rest.- Significant relationship but most likely state of incorporation

Question 6

MI Choice- Corporations External Affairs

Answer 6

General Choice of Law Rules

Sutherland Test

Question 7

MI Choice- Marriage

Answer 7

Marriage that is valid where celebrated is valid everywhere