Conflict of Laws

• rendering - making judgment
• recognizing - enforcing it

• proper Jx
• judgment on the merits (D.J. = merits)
• final judgment

• G: penal / extrinsic fraud
• B: tax judgemnt, pub pol, mistakes of law or fact

recognizing forgein judgments if due process (JX/sham procedures)

• proper JX if one was domiciled in rendering state
• estopped? (personal jx, meaningful role, privity w/ parties, marry/remarry)

• property: proper if PJ over spouse whose property rights @ issue
• custody: valid if rendering court is that of child's home state

if valid divorce decree but ancillary not (prop/cust) SEVERABLE. D valid, anc not

• infants (D with parents)
• mental incompetnets (D with parents)

• vested rights
• most sig. relationship
• governmental interest

• substantive area involved
• vesting rule (PISSED)
• who wins and result

"court will apply the law of the state which is most significantly related to the outcome of litigation. Court will look at the connecting facts and policy principles"

"will apply its own law as long as it has a legitimate interest in the outcome of the litigation. t it has non, this is a false conflict and will apply the law of another state"