## Facts

- Ralph A. Hague, a Wisconsin resident, was killed on July 1, 1974, when a motorcycle on which he was a passenger was rear-ended in Wisconsin by another Wisconsin driver.
- The motorcycle (owned and operated by Hague’s son) was uninsured; the striking automobile also lacked valid liability insurance.
- Hague held an Allstate automobile policy covering three cars, each with $15,000 uninsured-motorist coverage.
- Hague worked in Red Wing, Minnesota, and had done so for 15 years immediately before his death, commuting from Wisconsin.
- After the accident, Hague’s widow, Lavinia Hague, moved to Minnesota and later remarried and established residence there.
- A Minnesota probate registrar appointed Lavinia as personal representative of Hague’s estate.
- Wisconsin law at the time barred “stacking” multiple uninsured-motorist coverages; Minnesota law allowed stacking when separate coverages/premiums applied.

## Issues

1. Whether Minnesota or Wisconsin law governed interpretation of the uninsured-motorist provisions of Hague’s Allstate policy, including the availability of stacking.
2. Whether Minnesota’s conflicts methodology permitted application of Minnesota’s pro-stacking rule despite the policy’s Wisconsin delivery and the accident’s occurrence in Wisconsin.

## Decision

- The Minnesota Supreme Court affirmed summary judgment for the estate.
- The court held Minnesota law applied under Minnesota’s conflicts approach.
- Applying Minnesota law, the estate could stack the three $15,000 uninsured-motorist coverages for total coverage of $45,000.

## Legal Principles

- In insurance choice-of-law disputes, Minnesota applies an interest-based conflicts analysis that may include a “better law” evaluation when more than one state has meaningful connections.
- Minnesota may apply its insurance law when Minnesota has substantial contacts and a legitimate governmental interest (including regulation of insurers doing business in Minnesota and protection of persons with strong Minnesota ties).
- A multistate insurer issuing automobile coverage can reasonably anticipate that insured persons and vehicles will have interstate contacts; this reduces the weight of a single-state expectation tied to policy issuance.
- Under Minnesota uninsured-motorist law, separately purchased coverages may be stacked to reflect the protection purchased through multiple coverages/premiums.

## Conclusion

The court applied Minnesota’s conflicts analysis to select Minnesota law based on Minnesota’s contacts and interests and its preference for the pro-stacking rule, allowing the estate to aggregate three uninsured-motorist coverages into $45,000 of available benefits.


Hague v. Allstate Ins. Co., 289 N.W.2d 43 (Minn. 1978)