Berghammer v. Smith

What law applies to Lillian J. Bergham-mer’s claim for loss of consortium ?

The parties do not raise constitutional issues but are in disagreement as to the law which is applicable to that claim. Minnesota law appears to apply under the “most significant relationships” test. Fuerste v. Bemis, 156 N.W.2d 831 (Iowa). But what Minnesota law — the law which the Minnesota courts hold to be applicable or the law which we may differently hold to apply?

Involved here is a problem of the applicable law in two dimensions. Conventional conflict of laws principles deal with different laws geographically.…