## Facts

- Ralph Hague, a Wisconsin resident, worked in Minnesota and commuted across the state line.
- Hague was killed in Wisconsin when a motorcycle on which he was a passenger was struck by an автомобile; the accident occurred near the Minnesota border.
- At the time of the accident, Hague and the drivers involved were Wisconsin residents; neither driver had valid insurance.
- Hague held an Allstate policy issued in Wisconsin covering three automobiles, each with $15,000 in uninsured motorist coverage.
- After the accident, Lavina Hague moved to Minnesota, became a resident, and was appointed there as personal representative of Hague’s estate.
- She sued in Minnesota seeking to apply Minnesota law to “stack” the uninsured motorist coverages for a total of $45,000.
- Allstate argued Wisconsin law should apply because the policy was delivered in Wisconsin, the accident occurred in Wisconsin, and the relevant parties were Wisconsin residents when the accident occurred.
- Minnesota courts applied Minnesota law and permitted stacking; Allstate sought Supreme Court review alleging violations of the Due Process Clause and the Full Faith and Credit Clause.

## Issues

1. Whether Minnesota’s application of its stacking rule violated the Due Process Clause because Minnesota lacked sufficient contacts with the parties or occurrence.
2. Whether Minnesota’s application of its law violated the Full Faith and Credit Clause by failing to respect Wisconsin’s interests in applying its anti-stacking rule.

## Decision

- The Court affirmed the Minnesota Supreme Court’s judgment permitting application of Minnesota law.
- A plurality held Minnesota had a significant aggregation of contacts creating legitimate state interests, so applying Minnesota law was neither arbitrary nor fundamentally unfair under Due Process, and was permissible under Full Faith and Credit.
- The plurality relied on: Hague’s Minnesota employment, Allstate’s authorization and business operations in Minnesota, and Mrs. Hague’s post-accident Minnesota residency and estate administration there.
- Justice Stevens concurred in the judgment, emphasizing the absence of fundamental unfairness and the lack of a serious threat to interstate federalism interests.
- A dissent would have reversed, viewing Minnesota’s asserted contacts as insufficiently related to the insurance contract and as facilitating forum favoritism.

## Legal Principles

- A forum may apply its substantive law only if it has a significant contact or significant aggregation of contacts creating state interests, such that the choice is not arbitrary or fundamentally unfair.
- Due Process and Full Faith and Credit impose similar limits on choice of law: a state may not apply its law when it has only insignificant contacts with the parties and the occurrence or transaction.
- Full Faith and Credit does not require a forum to apply the law of the state with the greatest interest; it bars forum law only when the forum’s connection is too slight to justify its choice.
- Post-event contacts (such as a party’s relocation and estate administration in the forum) may count in the contact aggregation when genuine, and can support a forum’s regulatory and remedial interests.

## Conclusion

The Court upheld Minnesota’s application of its uninsured-motorist stacking rule because Minnesota’s combined contacts with the insured’s employment, the insurer’s in-state business, and the estate’s administration made the choice of Minnesota law constitutionally permissible under both Due Process and Full Faith and Credit.


Allstate Ins. Co. v. Hague, 449 U.S. 302 (1981)