Most Significant Relationship Approach

Question 1

Most Significant Relationship Approach

Answer 1

Apply the law of the state which has most significant relationship to the occurrence or transaction and the parties

Question 2

Most Significant Relationship Application

Answer 2

Controlling Principles
Relevant Contacts
Default Rules

Question 3

MSR Approach- Controlling Principles

Answer 3

Needs of the interstate and international judicial system
Relevant policies of the forum **
Relevant policies of other interested states **
Protection of justified expectations **
Basic policies underlying that field of law
Certainty, predictability and uniformity of result **
Ease of determining and applying the law chosen

Question 4

MSR- Relevant Contacts Torts

Answer 4

Where injury and conduct occurred
Parties’ domicile, residence, place of incorporation, place of business, and
Where parties relationship is centered

Question 5

MSR- RElevant Contacts KX

Answer 5

Where contracting, negotiation, and performance occur
Where the subject matter of Kx is located, and
Parties’ domicile, residence, place of inc. and place of business

Question 6

MSR- Default Rules

Answer 6

Usually coincides with vested rights rules