Klaxon

1
Klaxon

• Federal courts in diversity cases apply the
  choice of law rules of the state in which they
  sit
• Thus, the US District Courts in MO do not
  necessarily apply MO law
• Instead, they apply whatever law a MO state court
  would apply in the same case.

2
What if You Dont Know Klaxon

• Paul (PA) Deb (DE) agree to share PA lottery
  ticket proceeds
• Negotiations mainly in PA
• Acceptance in DE
• Choice of Law
• PA -- place of acceptance
• DE -- place of negotiations
• Substantive Law
• PA Unenforceable
• DE Enforceable

5,000,000
Paul Has the Ticket
Deb sues in DE Federal Ct