Allstate Insurance Co. v. Hague
Citation: 449 U.S. 302 (1981)
Facts
Ralph Hague, a Wisconsin resident, was killed in Wisconsin in a motorcycle accident. He was insured under three automobile policies issued by Allstate in Wisconsin. His widow later moved to Minnesota and sought to stack the three policies under Minnesota law, which permitted stacking; Wisconsin law did not. She filed suit in Minnesota.
Issue
Does application of Minnesota law to an insurance dispute with only post-accident connections to Minnesota violate the Due Process Clause or the Full Faith and Credit Clause?
Holding
No. A plurality of the Supreme Court upheld Minnesota’s application of its own law, finding that Minnesota had three relevant contacts — Hague’s commuting to work in Minnesota, Allstate’s doing business in Minnesota, and the widow’s post-accident relocation — that were sufficient to satisfy constitutional requirements.
Rule
A state’s choice of its own law is constitutionally permissible if the state has a “significant contact or significant aggregation of contacts” to the parties or the occurrence. The contacts need not be present before the accident; post-occurrence contacts may count.
Significance
Allstate v. Hague, read together with Phillips Petroleum, defines the constitutional outer limits of choice of law. The plurality’s loose treatment of contacts drew a sharp dissent and remains controversial. It illustrates that the constitutional minimum is quite permissive.