LEX LOCI CONTRACTUS, contracts.

The law of the place where an agreement is mad

e.
2. Generally, the validity of a contract is to be decided by the law of the place where,
the contract is made; if valid, there it is, in general,valid everywhere. Story, Confl. of Law
s, Sec. 242, and the cases there cited. And vice versa if void or illegal there, it is general
ly voideverywhere. Id Sec. 243; 2 Kent Com. 457; 4 M. R. 584; 7 M. R. 213; 11 M. R. 73
0; 12 M. R. 475; 1 N. S. 202; 5 N. S. 585; 6 N. S. 76; 6 L.R. 676; 6 N. S. 631; 4 Blackf.
R. 89.
Lex loci delictus means the law of the place where the plaintiff suffered the
wrong. It is the place where last event constituting the wrong takes place.
Courts follow the rule of lex loci delictus in determining which state's
substantive law is applicable to actions sounding in tort. The public policy
exception to lex loci delictus rule is where the law of the jurisdiction where
the tort occurred is against good morals or natural justice, or for some other
reason, its enforcement would be prejudicial to the general interests of our
citizens. [ Trahan v. E.R. Squibb & Sons, Inc., 567 F. Supp. 505 (D. Tenn.
1983)].
Kilberg Doctrine This is a rule applied in suits involving conflicts of law that
provides that the forum is not bound by the law of the place of injury or
death as to the limitation on damages for wrongful death action. The
rationale behind the doctrine is that laws that set limitations on damages are
procedural. Hence the law of the forum should govern the issue.
Center of gravity doctrine (most significant relationship theory; grouping
of contacts) - choice of law problems in conflict of laws are resolved by the
application of the law of the jurisdiction which has the most significant
relationship to or contact with event and parties to litigation and the issue
therein.
According to center of gravity doctrine, whenever there is a choice-of-law
question, the law of the jurisdiction with the most significant relationship to
the transaction or event applies.
Center-of-Gravity Doctrine is also known as significant-relationship theory or
grouping-of-contacts theory.