1. Leflar – choice influencing considerations
predictability of results
maintenance of interstate and int’l legal orders
simplification of judicial task
advancement of forum interest
choosing better rule of law

2. Dépeçage

3. Adams (NY domiciliary) is member of NY organization
Enrolls in its nature program
Truck takes him to Mass
Breaks down
Farmer with unregistered truck offers to take them the rest of way
Truck hits Adams, but not negligent
Mass law: driver unlicensed car is outlaw – liability w/o fault
NY requires negligence
Mass has charitable immunity
NY does not

4. renvoi désistement

5. Pfau v Trent Aluminum Co. (NJ 1970)

6. First, it is not definite that plaintiff would be unable to recover in either of those states. More importantly, however we, see no reason for applying Connecticut's choice-of-law rule. To do so would frustrate the very goals of governmental-interest analysis. Connecticut's choice-of-law rule does not identify that state's interest in the matter. Lex loci delicti was born in an effort to achieve simplicity and uniformity, and does not relate to a state's interest in having its law applied to given issues in a tort case.

7. Contract in CT, performance in Mass Mass court would use law of place of contracting CT court would use law of place of performance

8. - CA court is entertaining an action brought by a NY guest against an Ontario host concerning an accident in Ontario. - NY court would apply Ontario law - does that mean that a CA ct cannot apply NY law?

9. complex litigation

10. In re Air Crash Disaster near Chicago (7th Cir. 1981)