Conklin v. Horner

The defendants’ claim is based upon our decision in Wilcox v. Wilcox (1965), 26 Wis. 2d 617, 133 N. W. 2d 408, where we abandoned the choice-of-law rule of lex loci delicti and adopted in its stead a more flexible methodology based upon the qualitative analysis of the contacts that one or more jurisdictions might have with the relevant facts. We adopted the general approach of Babcock v. Jackson (1963), 12 N. Y. 2d 473, 240 N. Y. Supp. 2d 743, 191 N. E. 2d 279, 95 A. L. R. 2d 1, and the basic principle of Tentative Draft No. 9, Restatement,1 Conflicts of Laws 2d, which may be denominated as…