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accident alleged American Law Institute apply brought California cause of action choice of law choice-of-law claim Colum.L.Rev common law Conflict of Laws Constitution contract corporation Court of Appeals credit clause damages decedent decision decree defendant defendant's denied determine District Court divorce doctrine domicile due process effect enforce F.Supp fact faith and credit federal court Florida forum non conveniens full faith governed guest statute Harv.L.Rev husband Illinois injury interest International involved Iowa issue Jersey Judge jury Justice L.Ed L.Rev land liability limitations litigation Louisiana marriage Massachusetts ment negligence Nevada nonresident North Carolina NOTES obligation Ohio opinion parties Pennsylvania personal jurisdiction petitioner plaintiff problem procedure proceedings Professor of Law public policy question res judicata resident S.Ct Section spouse statute substantive suit supra Supreme Court Texas tion tort transaction trial trust United valid wife wrongful death York