The laws of other states and foreign nations shall have no force and effect of themselves within this state further than is provided by the Constitution of the United States and is recognized by the comity of states. The courts shall enforce this comity, unless restrained by the General Assembly, so long as its enforcement is not contrary to the policy or prejudicial to the interests of this state.
(Orig. Code 1863, § 10; Code 1868, § 9; Code 1873, § 9; Code 1882, § 9; Civil Code 1895, § 9; Civil Code 1910, § 9; Code 1933, § 102-110.)
Cross references.- Rights of citizens of other states or nations to sue or give evidence, § 1-2-10.
Uniform Foreign-Country Money Judgments Recognition Act, § 9-12-110 et seq.
Judicial enforcement of taxes imposed by other states, § 48-2-80.
Law reviews.- For article discussing convergence of standards governing limits of state's personal jurisdiction and applicability of state substantive law, see 9 J. of Pub. L. 282 (1960). For article advocating replacement of the lex loci delicti doctrine in Georgia with a national interest analysis approach, see 20 Mercer L. Rev. 1 (1969). For articles on conflict of law, see 34 Mercer L. Rev. 469 (1983) and 35 Mercer L. Rev. 417 (1984). For article discussing recent developments in the area of conflict of laws, see 39 Mercer L. Rev. 411 (1987). For article comparing "rules" and "analysis" approaches to choice of law, see 40 Mercer L. Rev. 869 (1989). For article, "An Essay on Illusion and Reality in the Conflict of Laws," see 70 Mercer L. Rev. 819 (2019). For note, "Interstitial Lawmaking: Uniformity or Conformity?" see 32 Mercer L. Rev. 1235 (1981).
JUDICIAL DECISIONSANALYSIS
Laws of other states have no force in Georgia except on principles of comity. Gulf Collateral, Inc. v. Morgan, 415 F. Supp. 319 (S.D. Ga. 1976).
Nature of comity.
- Comity is reciprocity. It cannot be that the laws of the several states of the union differ so materially in policy or in the nature of their institutions as to require that unquestionable defensive right of every sovereignty, that of protecting its citizens against the operation of the laws or doctrines of another state, incompatible with their safety, or injurious to their interest. Jackson v. Johnson, 34 Ga. 511, 89 Am. Dec. 263 (1866).
Comity requires that state courts be afforded opportunity to perform duties.
- Although the states are sovereign entities, they are bound along with their officials, including their judges, by the United States Constitution and the federal statutory law. Principles of comity in the United States federal system require that the state courts be afforded the opportunity to perform their duty, which includes responding to attacks on state authority based on the federal law, or, if the litigation is wholly private, construing and applying the applicable federal requirements. Webb v. Webb, 451 U.S. 493, 101 S. Ct. 1889, 68 L. Ed. 2d 392 (1981).
Public policy controlled over contract terms.
- In answering a question certified from a federal appeals court in an action concerning a noncompetition agreement, the Georgia Supreme Court held that, based on O.C.G.A. § 1-3-9, the law of the jurisdiction chosen by the parties to a contract to govern their contractual rights would not be applied by Georgia courts where application of the chosen law would contravene the policy of, or would be prejudicial to the interests of Georgia, and that covenants against disclosure and competition affected the interests of Georgia, namely the flow of information needed for competition among businesses, and hence their validity would be determined by the public policy of Georgia. Convergys Corp. v. Keener, 276 Ga. 808, 582 S.E.2d 84 (2003).
Workers' compensation.
- Employer who paid a workers' compensation claimant workers' compensation benefits under Texas law was not entitled to a subrogation claim to the proceeds of a tort settlement against the alleged tortfeasors under the full faith and credit and comity provisions of the U.S. Constitution. Tyson Foods, Inc. v. Craig, 266 Ga. App. 443, 597 S.E.2d 520 (2004).
Cited in Shore Acres Properties, Inc. v. Morgan, 44 Ga. App. 128, 160 S.E. 705 (1931); Patterson v. Patterson, 208 Ga. 7, 64 S.E.2d 441 (1951); R. & J. Dick Co. v. Bass, 295 F. Supp. 758 (N.D. Ga. 1968); Roadway Express, Inc. v. Warren, 163 Ga. App. 759, 295 S.E.2d 743 (1982); CS-Lakeview at Gwinnett, Inc. v. Simon Prop. Group, Inc., 283 Ga. 426, 659 S.E.2d 359 (2008); Global Link Logistics, Inc. v. Briles, 296 Ga. App. 175, 674 S.E.2d 52 (2009).
When Doctrine of Comity Invoked
1. General Rule
In enforcing comity, Georgia does so where not contrary to state policy.- In enforcing comity in respect to the laws of sister states, Georgia does so only so long as its enforcement is not contrary to the policy of this state. Gulf Collateral, Inc. v. Morgan, 415 F. Supp. 319 (S.D. Ga. 1976).
2. Right to Sue
State courts will not exclude Alabama suitors where Alabama courts do not exclude Georgia suitors.
- Only in this sense is the expression "reciprocity is comity" applicable to causes of action springing from wrongful deaths occurring in Alabama. Southern Ry. v. Decker, 5 Ga. App. 21, 62 S.E. 678 (1908).
If foreign appointed administrator becomes state resident, liable to be sued here.
- If an administrator appointed in Alabama, together with the securities on the administrator's bond, become residents of this state, they are liable to be sued here on a decree rendered in this state on a bill filed by the distributees for an account and settlement. Johnson v. Jackson, 56 Ga. 326, 21 Am. R. 285 (1876).
When receiver may sue in foreign jurisdiction.
- While a chancery or statutory receiver cannot sue in the courts of a foreign jurisdiction by virtue of the receiver appointment alone, the receiver can do so when the receiver is expressly authorized by statute to sue, or when the receiver is expressly or by necessary implication vested with title, or when the receiver is made a quasi-assignee or representative of creditors. Bullock v. Oliver, 155 Ga. 151, 116 S.E. 293, 29 A.L.R. 1484, answer conformed to, 30 Ga. App. 91, 117 S.E. 112 (1923).
3. Statutes, Laws, and Judgments
Foreign citizen cannot claim local garnishment exemption when property seized here.
- Under the comity of states, a citizen and resident of Alabama cannot claim the benefit of our exemption laws as against a garnishment when one's property happens to be seized on process here. In this respect "reciprocity is comity" according to this section. Kyle & Co. v. Montgomery, 73 Ga. 337 (1884).
Courts of Georgia will not be bound by interpretations of foreign state upon common law. Krogg v. Atlanta & W. Point R.R., 77 Ga. 202, 4 Am. St. R. 79 (1886).
Georgia must give full faith and credit to sister state's judgment.
- Even if the statutory law of this state is different from that of a sister state, and even if this would prevent recovery, the forum state (Georgia) must give full faith and credit to a judgment rendered by the sister state. Colodny v. Krause, 136 Ga. App. 379, 221 S.E.2d 239 (1975).
Judgment of foreign state construing corporate charter followed by state courts.
- A judgment rendered by the courts of a state in which a corporation is chartered, construing the charter with respect to the powers conferred therein, will be followed by the courts of this state. Clark v. Turner, 73 Ga. 1 (1884).
Georgia courts recognize and prospectively enforce foreign alimony or child support decree.
- Although a foreign decree may be nonfinal because it can be prospectively modified, for reasons of comity Georgia courts will recognize and give prospective enforcement to a foreign alimony or child support decree by establishing it as the decree of a Georgia court through domestication and treating it as though it were a local decree. Williamson v. Williamson, 247 Ga. 260, 275 S.E.2d 42, cert. denied, 454 U.S. 1097, 102 S. Ct. 669, 70 L. Ed. 2d 638 (1981).
Comity is not applied where foreign divorce is obtained under circumstances offending state's public policy as found in its Constitution and statutes and the decisions of its courts. Christopher v. Christopher, 198 Ga. 361, 31 S.E.2d 818 (1944).
4. Contracts
Law applicable in governing contracts.
- Contracts are to be governed as to their nature, validity, and interpretation by the law of the place where they were made, except where it appears from the contract that it is to be performed in a state other than that in which it was made, in which case the laws of that sister state will be applied in the enforcement of any contract to be there performed, so long as such laws do not conflict with the statute, powers, or rights of the state wherein it was executed and sought to be enforced. Tillman v. Gibson, 44 Ga. App. 440, 161 S.E. 630 (1931).
The conflicts rule in this state is that where a contract is made and is to be performed in another state, the laws of the latter state will govern as to the validity, nature, obligation, and construction of the contract, where they are duly pleaded and proved, and such laws will be enforced by comity in this state unless they are contrary to public policy or prejudicial to the interests of this state. Rohner, Gehrig & Co. v. Capital City Bank, 655 F.2d 571 (5th Cir. 1981).
Contracts made and performed in another state will be enforced unless such state's laws are contrary to Georgia public policy. Nationwide Gen. Ins. Co. v. Parnham, 182 Ga. App. 823, 357 S.E.2d 139 (1987).
Law applicable to contracts affecting property.
- As to contracts affecting realty, the law of the state where the land lies will be applied, and to all kinds of personal property, it is governed by the lex domicili of the owner. Clark v. Baker, 186 Ga. 65, 196 S.E. 750 (1938).
Foreign contract and laws enforced in this state.
- Whenever a contract made in a place outside of the territorial jurisdiction of this state is sought to be enforced in this state, courts here will enforce the contract and give effect to the laws of the place in which it was executed, so far as that can be done without violating the law of this state or its established policy. Massachusetts Benefit Life Ass'n v. Robinson, 104 Ga. 256, 30 S.E. 918, 42 L.R.A. 261 (1898).
Contracts made and performed in another state will be enforced unless such state's laws are contrary to the public policy of the enforcing state. Terry v. Mays, 161 Ga. App. 328, 291 S.E.2d 44 (1982).
Contract executed in foreign state, not intended as Georgia contract, treated as foreign contract.
- Where a contract not only is executed in a foreign state, but contains nothing to indicate by the place of performance or otherwise that it was intended to be construed as a Georgia contract, it will be treated as a contract of the foreign state and governed by its laws. Trustees of Jesse Parker Williams Hosp. v. Nisbet, 189 Ga. 807, 7 S.E.2d 737 (1940); Terry v. Mays, 161 Ga. App. 328, 291 S.E.2d 44 (1982).
Foreign marriage settlement applicable to Georgia lands.
- A marriage settlement executed between persons who were then and continued to be citizens of South Carolina applied to lands situated in Georgia according to South Carolina inheritance laws. Brown v. Ransey, 74 Ga. 210 (1884).
State's public policy is generally limited to enforcement of money contracts performed in this state, and public policy does not extend to the enforcement of valid contracts made in other states, for which the rules of comity will be observed. Commercial Credit Plan, Inc. v. Parker, 152 Ga. App. 409, 263 S.E.2d 220 (1979).
Effect of statutory prohibition in enforcing state.
- A contract is not necessarily contrary to the public policy of the enforcing state merely because it could not validly have been made there, notwithstanding the making of such contracts in the place of the forum is expressly prohibited by statute. Terry v. Mays, 161 Ga. App. 328, 291 S.E.2d 44 (1982).
Contract provision regarding support following artificial insemination.
- A Florida contract under which a mother relinquished her right to hold a sperm donor responsible for any resulting child was not unenforceable under O.C.G.A. § 1-3-9 as contrary to public policy. The contract was authorized by Florida law, and Georgia had held that paternity through artificial insemination did not confer responsibility for support. Brown v. Gadson, 288 Ga. App. 323, 654 S.E.2d 179 (2007), cert. denied, No. S08C0456, 2008 Ga. LEXIS 236 (Ga. 2008).
5. Property
Assets of deceased distributed according to law of state where representatives appointed.
- The assets of the deceased should be applied to the payment of debts, or be distributed amongst the next of kin, by the courts of this state according to the law of the state where the representatives were appointed. This is the comity of states as recognized by this section. Johnson v. Jackson, 56 Ga. 326, 21 Am. R. 285 (1876).
Right and disposition of personalty is to be governed by the law of the domicile of the owner, and not the law of the location of the property. Grote v. Pace, 71 Ga. 231 (1883).
When Doctrine of Comity Not Invoked
1. General Rule
Our courts are not required by comity to enforce what is not law in other state. Tennessee v. Virgin, 36 Ga. 388 (1867).
Foreign law not enforced if penal only, or if contravenes established public policy.
- A foreign law will not be enforced if it is penal only and relates to the punishing of public wrongs as contradistinguished from the redressing of private injuries, or if it contravenes our established public policy, or the recognized standards of civilization and good morals. Eubanks v. Banks, 34 Ga. 407 (1866); Reeves v. Southern Ry., 121 Ga. 561, 49 S.E. 674, 70 L.R.A. 513, 2 Ann. Cas. 207 (1905); Southern Ry. v. Decker, 5 Ga. App. 21, 62 S.E. 678 (1908).
Foreign law will not be enforced if it is penal only and relates to the punishing of public wrongs as contradistinguished from the redressing of private injuries. Laminoirs-Trefileries-Cableries de Lens, S.A. v. Southwire Co., 484 F. Supp. 1063 (N.D. Ga. 1980).
Foreign laws not enforced if immoral or violative of conscience.- Where the law of a sister state contravenes the public policy of Georgia or is immoral or violative of conscience, it will not be enforced in this state. Gulf Collateral, Inc. v. Morgan, 415 F. Supp. 319 (S.D. Ga. 1976).
In diversity cases, governing law that of state in which federal court sits.- There has been no repeal or modification of the principle that enforcement of the laws of another state is not required where they run counter to the public policy of Georgia. In diversity cases involving that issue, the governing law is that of the state in which the federal court is sitting. Gulf Collateral, Inc. v. Morgan, 415 F. Supp. 319 (S.D. Ga. 1976).
2. Statutes and Judgments
Foreign legislature cannot prescribe laws to be recognized and enforced in courts of this state, even though the law as to which cognizance is sought to be excluded is a statute of the state whose legislature seeks to create the exclusion. Southern Ry. v. Decker, 5 Ga. App. 21, 62 S.E. 678 (1908).
Comity cannot be invoked to give extraterritorial effect to a judgment procured by fraudulent representations in order to obtain jurisdiction of the court. Christopher v. Christopher, 198 Ga. 361, 31 S.E.2d 818 (1944).
Indiana products liability law contravened Georgia public policy.
- Public policy exception to lex loci delicti applied and Georgia law should have been applied in a design defect products liability case because Georgia recognized strict liability in such cases, pursuant to O.C.G.A. § 51-1-11, whereas Indiana law required a showing that the manufacturer failed to exercise reasonable care under the circumstances. Bailey v. Cottrell, Inc., 313 Ga. App. 371, 721 S.E.2d 571 (2011).
Belize wrongful death statute would not be enforced as against public policy.
- Although Belize law's 12-month statute of limitations for a wrongful death claim was substantive, not procedural, and a mother's wrongful death claim arising out of her son's drowning death in Belize was filed outside the 12-month period, the court refused to enforce Belize law under O.C.G.A. § 1-3-9, because the wrongful death statute was against Georgia public policy in that it allowed for damages only from the perspective of the survivors. Forbes v. Auld, 351 Ga. App. 555, 830 S.E.2d 770 (2019).
3. Contracts
Law chosen by parties not applied where contravenes state interests.
- The law of the jurisdiction chosen by the parties to a contract to govern their contractual rights will not be applied by the Georgia courts where the application of the chosen law would contravene the policy of, or would be prejudicial to, the interests of this state. Dothan Aviation Corp. v. Miller, 620 F.2d 504 (5th Cir. 1980).
Comity cannot be invoked in aid of award, where illegal transaction was submitted to arbitrators. Benton & Brother v. Singleton, 114 Ga. 548, 40 S.E. 811, 58 L.R.A. 181 (1902).
Stipulations in foreign contract arbitrarily limiting negligence liability of common carrier not enforced.
- So far as stipulations of a contract limit the common-law liability of the carrier as an insurer, or for losses occurring by unavoidable accident, they will be enforced by the courts of this state; but in such a case, it being contrary to the public policy of this state to allow a common carrier, even by express contract, to make an arbitrary limitation upon its liability for negligence of its agents or servants, stipulations to that effect will not be enforced. Southern Express Co. v. Hanaw, 134 Ga. 445, 67 S.E. 944, 137 Am. St. R. 227 (1910).
Neither is foreign law providing married woman liable upon suretyship contract.
- The law of a foreign state providing that a married woman is liable upon her contract of suretyship will not be enforced in this state under this section. Sally v. Bank of Union, 25 Ga. App. 509, 103 S.E. 798 (1920); Ulman, Magill & Jordan Woolen Co. v. Magill, 155 Ga. 555, 117 S.E. 657 (1923).
Foreign carriage contract not necessarily governed by foreign laws where partly performed in state.
- Though a contract of carriage is made in a foreign state, it is not necessarily governed in matters of construction and effect by the laws of that state, where the contract is to be partly performed in this state. Myers v. Atlantic Greyhound Lines, 52 Ga. App. 698, 184 S.E. 414 (1936).
Foreign provision providing that surety or obligor not released along with cosurety or coobligor unenforceable.
- A Tennessee statute providing that the release of a cosurety or coobligor does not release the other surety or obligor when the parties, other than those not released, stipulate that the other surety or obligor is not released is contrary to the public policy of this state and will not be enforced. Kent v. Hair, 60 Ga. App. 652, 4 S.E.2d 703 (1939).
Gambling transactions contravene the public policy of Georgia and constitute obligations unenforceable in its courts. Gulf Collateral, Inc. v. Morgan, 415 F. Supp. 319 (S.D. Ga. 1976).
Validity of covenants against disclosure determined by state's public policy.
- Covenants against disclosure, like covenants against competition, affect the interests of this state, namely the flow of information needed for competition among businesses, and hence their validity is determined by the public policy of this state. Nasco, Inc. v. Gimbert, 239 Ga. 675, 238 S.E.2d 368 (1977).
Validity of covenants against competition determined by state's public policy.- Covenants against competition affect the interests of this state, hence their validity is determined by the public policy of this state. Dothan Aviation Corp. v. Miller, 620 F.2d 504 (5th Cir. 1980).
4. Property
Comity not applicable to suit by receiver unless appointment provision vests property title in receiver.
- The principles of comity do not apply to a suit by a chancery receiver in a foreign jurisdiction, nor to a suit by a statutory receiver, unless the statute under which the receiver is appointed vests title in the receiver to the property the receiver represents. Oliver v. Bullock, 28 Ga. App. 446, 111 S.E. 680 (1922), rev'd on other grounds, 155 Ga. 151, 116 S.E. 293, 29 A.L.R. 1484, answer conformed to, 30 Ga. App. 91, 117 S.E. 112 (1923).
State has no jurisdiction to bring foreign administrator to account where the administrator is visiting here on business. Jackson v. Johnson, 34 Ga. 511, 89 Am. Dec. 263 (1866).
Provisions of foreign will contrary to state policy not enforced.
- Our laws will not enforce the provisions of a will made in another state which are directly contrary to the declared policy of this state, but the judgment of a competent tribunal as to the will, where the will was executed, will be respected by the courts of this state. Caruthers v. Corbin, 38 Ga. 75 (1868).
Pleading and Proving Foreign Law
Foreign law must be pled and proved.
- Where a party seeks to rely on the law of another state as furnishing the basis for a right of recovery or defense different from what it would be under the laws of this state, or the common law, the law of the foreign state should be pled and proved. Southern Express Co. v. Hanaw, 134 Ga. 445, 67 S.E. 944, 137 Am. St. R. 227 (1910).
Where pled, decisions of foreign courts of last resort adopted in construing statute.
- Where a statute of a foreign state is pled as being the basis of a cause of action arising in that state, in a suit instituted in this state, and a construction of the statute becomes necessary, the decisions of the courts of last resort of the foreign state in construing the statute will be adopted; and where it appears that there are no decisions of the courts in that state construing the statute, but that the statute was verbally adopted from the statute of another state, the decisions of the state from which it was adopted will be considered in construing the statute, especially those decisions construing it which had been made prior to the adoption of the statute in the latter state. Lee v. Lott, 50 Ga. App. 39, 177 S.E. 92 (1934).
Foreign judgment, if proved, may have effect of former local adjudication.
- Under the full faith and credit clause of the Constitution, a judgment of a court of competent jurisdiction in Tennessee, if properly proved, may have the effect of a former adjudication in matters pending in the courts of this state. Roadway Express, Inc. v. McBroom, 61 Ga. App. 223, 6 S.E.2d 460 (1939).
Laws of state of contract's performance, where proved, govern validity, nature, obligation, and construction.
- Where a contract is made in one state to be performed in another, the laws of the latter state will govern as to the validity, nature, obligation, and construction of the contract, where they are duly pleaded and proved, and such laws will be enforced by comity in this state unless they are contrary to public policy or prejudicial to the interests of this state. Pratt v. Sloan, 41 Ga. App. 150, 152 S.E. 275 (1930).
Where a contract is made in one state to be performed in another, the laws of the latter state will govern as to the validity, nature, obligation, and construction of the contract, when they are pleaded and proved, and this general rule is particularly applicable to liability for a passenger's baggage. Myers v. Atlantic Greyhound Lines, 52 Ga. App. 698, 184 S.E. 414 (1936).
Contract of foreign state originally part of colonies governed by common law, absent contrary pleading.
- A contract of a foreign state which constituted one of the original 13 colonies, or which was derived from territory included in one of the colonies, will be construed and governed by the common law, in the absence of any pleading to the contrary, and in such a case, the construction of the common law given by the courts of this state will control, in preference to the construction given by the courts of the state of the contract. Trustees of Jesse Parker Williams Hosp. v. Nisbet, 189 Ga. 807, 7 S.E.2d 737 (1940).
Foreign law must be pleaded where state never part of English territory.
- In an action on a contract of a state that was never a part of English territory, embraced in one of the original 13 colonies or belonging thereto, the law of the foreign state must be pleaded, in the absence of which it will be presumed that the law of this state obtains therein. Trustees of Jesse Parker Williams Hosp. v. Nisbet, 189 Ga. 807, 7 S.E.2d 737 (1940).
RESEARCH REFERENCES
Am. Jur. 2d.
- 16 Am. Jur. 2d, Conflict of Laws, § 7 et seq. 16B Am. Jur. 2d, Constitutional Law, § 1025 et seq. 44B Am. Jur. 2d, International Law, §§ 1 et seq., 13 et seq.
C.J.S.- 15A C.J.S., Conflict of Laws, §§ 1 et seq., 6 et seq. 48 C.J.S., International Law, §§ 5 et seq., 22 et seq., 26 et seq.
ALR.
- Statute relating to liability of officers or directors of private corporation as penal within principle that penal laws will not be enforced extraterritorially, 25 A.L.R. 1428.
Conflict of laws as to contributory negligence, 32 A.L.R. 796.
Extraterritorial effect of confiscations of property and nationalization of corporations, 37 A.L.R. 726; 41 A.L.R. 745; 65 A.L.R. 1494; 139 A.L.R. 1209.
Reciprocity as affecting comity, 50 A.L.R. 30; 87 A.L.R. 973.
Inhibition by decree of divorce or statute of state or country in which it is granted, against remarriage, as affecting a marriage celebrated in another state or country, 51 A.L.R. 325.
Effect in third state of marriage valid where celebrated but void by law of domicile of parties, 51 A.L.R. 1412.
Applicability to contracts made or to be performed in another state or country, of a statute of the forum permitting persons injured to maintain action directly against indemnity insurer, 54 A.L.R. 515; 120 A.L.R. 855.
Death statute as a penal law within the rule that courts of one state or country will not enforce penal laws of another, 62 A.L.R. 1330.
Limitation applicable to cause of action created by statute of another state which allows a longer period than the statute of the forum, 68 A.L.R. 217; 146 A.L.R. 1356.
Bar of statute of nonclaim of decedent's domicile as affecting assertion of claim elsewhere, 72 A.L.R. 1030.
Duty of courts to follow decisions of other states, on questions of common law or unwritten law, in which the cause of action had its situs, 73 A.L.R. 897.
Conflict of laws as to character, form, and nature of action that may be brought upon a foreign contract, 74 A.L.R. 1331.
Nature of differences between lex loci and lex fori which will sustain or defeat jurisdiction of a cause of action for death arising under the law of another state or country, 77 A.L.R. 1311.
Conflict of laws as to construction and effect of will devising real property, 79 A.L.R. 91.
Action in one state or country on bond given pursuant to statute of another, 85 A.L.R. 847.
Jurisdiction of federal court or court of sister state of proceedings pursuant to state or foreign statute to compel arbitration, 85 A.L.R. 1124.
Right of personal representative appointed at the forum or in a jurisdiction where decedent was domiciled or where the tort occurred, to maintain action for death under foreign statute which provides that the action shall be brought by executor or administrator, 85 A.L.R. 1231; 52 A.L.R.2d 1170.
Conflict of laws as regards survival of cause of action and revival of pending action upon death of party, 87 A.L.R. 852; 42 A.L.R.2d 1170.
Conflict of laws as to conditional sale of chattels, 87 A.L.R. 1308; 13 A.L.R.2d 1312.
Assumption of or refusal to assume jurisdiction by court of one state or country, of action on contract involving foreign elements, 87 A.L.R. 1425; 90 A.L.R.2d 1109.
Lex loci or lex fori as the governing law as to whether the case or question is to be submitted to the jury or determined by the court, 89 A.L.R. 1278; 149 A.L.R. 775.
Conflict of laws as to period of limitation to enforce stockholders' statutory liability, 113 A.L.R. 510; 143 A.L.R. 1442.
Recognition of foreign marriage as affected by policy in respect of incestuous marriages, 117 A.L.R. 186.
Conflict of laws as to usury, 125 A.L.R. 482.
Constitutionality, construction, and application of compacts and statutes involving co-operation between states, 134 A.L.R. 1411.
Conflict of laws regarding deficiency in respect of debt secured by mortgage or deed of trust, 136 A.L.R. 1057.
Conflict of laws as to trusts inter vivos, 139 A.L.R. 1129.
Duty of courts of one state to recognize and give effect to decrees of divorce rendered in other states, as affected by constructive service of process or lack of domicile at divorce forum, 143 A.L.R. 1294; 1 A.L.R.2d 1385; 28 A.L.R.2d 1303.
Conflict of laws as to exercise of power of appointment, 150 A.L.R. 519.
Recognition of status created by foreign adoption or legitimation for purposes of testate or intestate distribution of decedent's estate in a jurisdiction in which such status could not have been created even in the case of one domiciled there, 153 A.L.R. 199.
Conflict of laws as regards brokerage contracts, 159 A.L.R. 266.
Enforceability of federal penal statutes in state courts, 162 A.L.R. 373; 172 A.L.R. 231.
Estoppel to assert invalidity of decree of divorce for lack of domicile at the divorce forum or failure to obtain jurisdiction of person, 175 A.L.R. 538.
Inclusion in domestic judgment or record, in action upon a judgment of a sister state, of findings respecting the cause of action on which the judgment in the sister state was rendered, 10 A.L.R.2d 435.
Conflict of laws as to chattel mortgages and conditional sales of chattels, 13 A.L.R.2d 1312.
Law governing validity and construction of, and rights and obligations arising under, a lease of real property, 15 A.L.R.2d 1199.
Conflict of laws as to survival or revival of wrongful death actions against estate or personal representative of wrongdoer, 17 A.L.R.2d 690.
Stay of civil proceedings pending determination of action in another state or country, 19 A.L.R.2d 301.
Conflict of laws as to partnership matters, 29 A.L.R.2d 295.
Conflict of laws as to elements and measure of damages recoverable for breach of contract, 50 A.L.R.2d 227.
Enforceability of provision in agreement for attorney's fees, valid in state of its execution or performance, but invalid under law of forum, 54 A.L.R.2d 1053.
What law governs employee's right to damages for wrongful discharge, 61 A.L.R.2d 917.
What law governs as to proper party plaintiff in contract action, 62 A.L.R.2d 486.
Right of state or its political subdivision to maintain action in another state for support and maintenance of defendant's child, parent, or dependent in plaintiff's institution, 67 A.L.R.2d 771.
Conflict of laws as to interest recoverable as part of the damages in a tort action, 68 A.L.R.2d 1337.
What law governs effect of release of one tort-feasor upon liability of another tort-feasor, 69 A.L.R.2d 1034.
Conflict of laws as to group insurance, 72 A.L.R.2d 695.
Extraterritorial recognition of, and propriety of counterinjunction against, injunction against actions in courts of other states, 74 A.L.R.2d 828.
Presumption as to law of foreign countries, 75 A.L.R.2d 529.
Choice of law in application of automobile guest statutes, 95 A.L.R.2d 12.
Law governing assignment of wages or salary, 1 A.L.R.3d 927.
Modern status of rule that substantive rights of parties to a tort action are governed by the law of the place of the wrong, 29 A.L.R.3d 603; 63 A.L.R.4th 167.
Conflict of laws as to presumptions and burden of proof concerning facts of civil case, 35 A.L.R.3d 289.
Conflict of laws as to right of action for loss of consortium, 46 A.L.R.3d 880.
Choice of law as to application of comparative negligence doctrine, 86 A.L.R.3d 1206.
Modern status of choice of law in application of automobile guest statutes, 63 A.L.R.4th 167.