Choice of law can lead to some thorny, but important, issues. In Federal cases with state law claims based on diversity or supplemental jurisdiction, the Federal court will look to the conflicts of laws rules of the forum state. See, e.g., Klaxon v. Stentor Elec. Mfg. Co., 313 U.S. 487, 495-97 (1941) (diversity); Bancoklahoma Mtg. Corp. v. Capital Title Co., Inc., ...
Choice of law can lead to some thorny, but important, issues. In Federal cases with state law claims based on diversity or supplemental jurisdiction, the Federal court will look to the conflicts of laws rules of the forum state. See,…