## Facts

- Timothy W. Jepson, a Minnesota domiciliary, owned and operated two North Dakota corporations.
- General Casualty issued an automobile liability policy naming Jepson, his spouse, and the corporations as insureds; the policy was procured through a Minnesota agency.
- The policy listed a Fargo, North Dakota address for the named insureds, insured seven vehicles, and covered a policy period from March 1983 to March 1984.
- Six vehicles were registered in North Dakota and one in Indiana; none were registered in Minnesota.
- Premiums were calculated at North Dakota rates and paid by a corporation; the policy included North Dakota-specific endorsements, including personal injury protection.
- In 1983, Jepson was injured as a passenger in an automobile accident in Arizona and settled claims against the tortfeasor and the tortfeasor’s insurer in North Dakota.
- Jepson filed a Minnesota declaratory judgment action seeking underinsured motorist (UIM) benefits and sought to stack UIM coverages across the seven vehicles.
- At the time, North Dakota law enforced UIM anti-stacking provisions, while Minnesota law permitted stacking.
- The trial court and court of appeals applied Minnesota law and allowed stacking; the insurer sought further review.

## Issues

1. Whether Minnesota or North Dakota law governs enforceability of the policy’s UIM anti-stacking provisions under Minnesota’s conflict-of-laws methodology.
2. Whether applying Minnesota stacking rules would improperly defeat contractual expectations and another state’s insurance regulatory choices in a multistate policy rated as a North Dakota risk.

## Decision

- The Minnesota Supreme Court held that North Dakota law governs the stacking issue.
- The court vacated the lower courts’ judgment and remanded for proceedings consistent with application of North Dakota law.
- Because North Dakota law enforces anti-stacking provisions, Jepson was not entitled to stacked UIM benefits; any Minnesota-law stacking analysis was moot.

## Legal Principles

- Minnesota resolves choice-of-law questions by evaluating five choice-influencing considerations: predictability of results; maintenance of interstate and international order; simplification of the judicial task; advancement of the forum’s governmental interest; and application of the better rule of law.
- In insurance-contract conflicts, contacts showing where the risk is located and how the policy was rated and structured are central to predictability and the parties’ reasonable expectations.
- Maintenance of interstate order favors applying the law of the state with the stronger regulatory relationship to the insured risk and disfavors outcomes driven primarily by forum selection.
- The “better rule of law” factor does not automatically prefer forum law and is not controlling where neither competing rule is clearly superior.

## Conclusion

Applying Minnesota’s choice-influencing considerations, the court treated the policy as principally a North Dakota risk and held that North Dakota law controls UIM stacking, rendering the policy’s anti-stacking provisions enforceable and defeating the claim for stacked benefits.


Jepson v. Gen. Cas. Co. of Wis., 513 N.W.2d 467 (Minn. 1994)