conflict of laws analysis (Texas) · Go Syfert
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conflict of laws analysis in Texas

22 Texas opinions name it 3 courts 1968–2024 3 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (17)

CaseFollowedCited
Alejandro Vivanco Alarcon as of the Estate of Araceli Alarcon Velazquez, Marie Eugenie Alarcon Velazquez, and Robert Blaauw as Receiver for Zalinco Corporation, N v. and Ocana Corporation, N v. v. Gabriel Alarcon Velazquezgreen
texapp · 2018 · cited in 4 Texas opinions naming this issue, 2019–2024
2 sentences

2024See Alarcon v. Velazquez, 552 S.W.3d 354, 360 (Tex. App.—Houston [14th Dist.] 2018, pet. denied) (“The Restatement methodology requires a separate conflict-of-laws analysis for each issue in a case.”); see also BDO Seidman, LLP v. Bracewell & Patterson, LLP, No. 05-02-00636-CV, 2003 WL 124829 , at *2 (Tex. App.—Dallas Jan. 16, 2003, pet. denied) (mem. op., not designated for publication) (“[T]he substantive law applicable to the underlying tort action is not automatically applicable to a defendant’s contribution claim.”).

2024See Alarcon v. Velazquez, 552 S.W.3d 354, 360 (Tex. App.—Houston [14th Dist.] 2018, pet. denied) (“The Restatement methodology requires a separate conflict-of-laws analysis for each issue in a case.”); see also BDO Seidman, LLP v. Bracewell & Patterson, LLP, No. 05-02-00636-CV, 2003 WL 124829 , at *2 (Tex. App.—Dallas Jan. 16, 2003, pet. denied) (mem. op., not designated for publication) (“[T]he substantive law applicable to the underlying tort action is not automatically applicable to a defendant’s contribution claim.”).

44
Weatherly v. Deloitte & Touchegreen
texapp · 1995 · cited in 3 Texas opinions naming this issue, 2004–2020
2 sentences

2020Weatherly v. Deloitte & Touche, 905 S.W.2d 642, 650 (Tex. App.—Houston [14th Dist.] 1995), subsequent mandamus proceeding sub nom.

2005See Weatherly, 905 S.W.2d at 650 .

33
Solano v. Gulf King 55, Inc.green
ca5 · 2000 · cited in 2 Texas opinions naming this issue, 2012–2012
2 sentences

2012Though the relators are Texas corporations who made allegedly negligent decisions that allegedly led to the explosion on the Supe, considering all of the Lauritzen- Rhoditis factors, we conclude as a matter of law that Peruvian law applies to the real parties‘ claims.7 See Solano, 212 F.3d at 905–07 (holding as a matter of law that Nicaraguan law applied rather than American law to personal-injury claims brought by 7 Even if we conducted the conflict-of-laws analysis under Texas principles, these principles are similar to the Lauritzen-Rhoditis factors, and we would reach the same conclusion u

2012See Solano, 212 F.3d at 905 .

22
In Re ENSCO Offshore International Co.green
tex · 2010 · cited in 2 Texas opinions naming this issue, 2012–2012
2 sentences

2012See Ensco, 311 S.W.3d at 928 . 15 Nicaraguan citizens allegedly injured in Nicaragua aboard vessels owned by American companies); Ali v. The Offshore Co., 753 F.2d 1327 , 1331–32 (5th Cir. 1985) (holding that the law of Trinidad applied to wrongful-death claims brought by widows of deceased citizens of Trinidad who died in the territorial waters of Trinidad aboard a drilling vessel owned by a Liberian company, an affiliate of various American companies who also were sued), overruled on other grounds by In re Air Crash Disaster Near New Orleans, La.

2012See Ensco, 311 S.W.3d at 928 .

22
cluster 552368green
ca5 · 1991 · cited in 2 Texas opinions naming this issue, 2012–2012
2 sentences

2012See Fogleman v. ARAMCO, 920 F.2d 278 , 283 (5th Cir. 1991).

2012See Fogleman v. ARAMCO, 920 F.2d 278 , 283 (5th Cir. 1991).

22
Hebert v. Kerr-McGee Corp.green
lawd · 1985 · cited in 2 Texas opinions naming this issue, 2002–2002
2 sentences

2002As explained above, if the place of performance and location of the contract's subject matter is where the indemnitee is sued, as the majority holds, then these factors point to no particular state under the conflict-of-laws analysis. [6] See Restatement (Second) of Conflict of Laws § 188 cmt. (e), at 580; accord Hebert, 618 F.Supp. at 772 .

2002As explained above, if the place of performance and location of the contract’s subject matter is where the in-demnitee is sued, as the majority holds, then these factors point to no particular state under the conflict-of-laws analysis. 6 See Restatement (Second) of Conflict of Laws § 188 cmt. (e), at 580; accord Hebert, 618 F.Supp. at 772 .

22
cluster 291420green
ca3 · 1970 · cited in 2 Texas opinions naming this issue, 2002–2002
2 sentences

2002See Gorsalitz, 429 F.2d at 1035-36, 1048.

2002See Gorsalitz, 429 F.2d at 1035-36, 1048.

22
Greenberg Traurig of New York, P.C. v. Moodygreen
texapp · 2005 · cited in 3 Texas opinions naming this issue, 2009–2019
2 sentences

2019“The Restatement methodology requires a separate conflict-of-laws analysis for each issue in a case.” Alarcon v. Velazquez, 552 S.W.3d 354, 360 (Tex. App.—Houston [14th Dist.] 2018, pet. denied) (citing Greenberg Traurig of N.Y., P.C. v. Moody, 161 S.W.3d 56, 70 (Tex. App.—Houston [14th Dist.] 2004, no pet.)); BDO Seidman, LLP v. Bracewell & Patterson, LLP, No. 05-02- 00636-CV, 2003 WL 124829 , at *2 (Tex. App.—Dallas Jan. 16, 2003, pet. denied) (mem. op.) (“[T]he substantive law applicable to the underlying tort action is not automatically applicable to a defendant’s contribution claim.”).

2009The court noted as an “important distinction” that “greatly impacts the conflict-of-laws analysis” that the investor plaintiffs had no contact and no direct dealings with the defendant New York law firm, and the representations alleged to have been made by the law firm “were not directed to Texas.” Greenberg Traurig, 161 S.W.3d at 72-73 .

13
Bain v. Honeywell International, Inc.green
txed · 2002 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019In addressing choice of law issues, “it is necessary for the court to analyze liability and damages separately.” Bain, 257 F.Supp.2d at 875 (citation omitted).

11
Young Refining Corp. v. Pennzoil Co.green
texapp · 2001 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Young Refining Corp. v. Pennzoil Co., 46 S.W.3d 380, 385 (Tex. App.—Houston [1st Dist.] 2001, pet. denied).

11
Hill v. Perelgreen
texapp · 1996 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015However, even this scenario has been specifically address by the First Court of Appeals with the conclusion that “[q]uestions of substantive law are controlled by the laws of the state where the cause of action arose, but matters of remedy and procedure are governed by the laws of the state where the action is sought to be maintained.” Hill v. Perel, 923 S.W.2d 636, 639 (Tex. App.—Houston [1st Dist.] 1995, no pet.). 25 of Kansas and Texas are so similar that there is in fact no conflict of laws problem present, and therefore, there is no need to even engage in a conflict of laws analysis.

11
Vanderbilt Mortgage & Finance, Inc. v. Poseygreen
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Each of those states has strong criminal sanctions and fully viable tor~ to which authorize these claims; and, justice requires the application of that tor~which affords to Plaintiffs the fairest and fullest opportunity to be made whole. ~ However, in Vanderbilt J. & Fin., Inc. v. Posey, 146 S.W.3d 302, 313 (Tex. App.-Texarkana 2004, no pe~e court noted that before a conflict of laws analysis commences: <Rl" ©!~ "The first ste Qeciding choice of law is whether the laws of the various jurisdictions - flict.

11
Vega v. Stategreen
texcrimapp · 2002 · cited in 1 Texas opinions naming this issue, 2008–2008
2 sentences

2008In its opinion, the court determined that procedural issues in this case were governed by the law of Texas, the forum state, and that substantive issues were also governed by Texas law because the conflict-of-law schemes of both Illinois and Texas militate for such application. 4 See id. at 617 ; see also id. at 621 (Keller, J., dissenting).

2008In its opinion, the court determined that procedural issues in this case were governed by the law of Texas, the forum state, and that substantive issues were also governed by Texas law because the conflict-of-law schemes of both Illinois and Texas militate for such application. 4 See id. at 617 ; see also id. at 621 (Keller, J., dissenting).

11
Gutierrez v. Collinsgreen
tex · 1979 · cited in 1 Texas opinions naming this issue, 2003–2003
1 sentence

2003See Gutierrez v. Collins, 583 S.W.2d 312, 319 (Tex.1979) (holding, absent statutory directive, all conflicts cases sounding in tort governed by “most significant relationship” test enunciated in sections 6 and 145 of Restatement (Second) of Conflicts).

11
Maxus Exploration Co. v. Moran Bros., Inc.green
tex · 1991 · cited in 1 Texas opinions naming this issue, 2002–2002
2 sentences

2002See id.

2002See id.

11
Loughran v. Loughrangreen
scotus · 1934 · cited in 1 Texas opinions naming this issue, 1971–1971
1 sentence

1971See, =.q., Louahran v. Loushran, 292 U.S. 216 , a. denied, 292 U.S. 615 (1934): Vickers v. Faubion, 224 S.W. 803 (Tex.Civ,App. 1920, no writ).

11
Wahlgren v. Bausch & Lomb Optical Co.green
scotus · 1934 · cited in 1 Texas opinions naming this issue, 1971–1971
1 sentence

1971See, =.q., Louahran v. Loushran, 292 U.S. 216 , a. denied, 292 U.S. 615 (1934): Vickers v. Faubion, 224 S.W. 803 (Tex.Civ,App. 1920, no writ).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Edgar v. Mite Corp. green
scotus · 1982
2 sentences

2017Co. v. Lopez, 156 S.W.3d 550 , 557 n.7 (Tex. 2004) (“The internal affairs doctrine is a conflict of laws principle which recognizes that only one State should have the authority to regulate a corporation’s internal affairs— matters peculiar to the relationships among or between the corporation and its current officers, directors, and shareholders... .”) (quoting Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982)); In re Crown Castle Int’l Corp., 247 S.W.3d at 354 ; see also In re Skyport Glob.

2017Co. v. Lopez, 156 S.W.3d 550 , 557 n.7 (Tex. 2004) (“The internal affairs doctrine is a conflict of laws principle which recognizes that only one State should have the authority to regulate a corporation’s internal affairs— matters peculiar to the relationships among or between the corporation and its current officers, directors, and shareholders... .”) (quoting Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982)); In re Crown Castle Int’l Corp., 247 S.W.3d at 354 ; see also In re Skyport Glob.

22004–2017
State Farm Mutual Automobile Insurance Co. v. Lopez green
tex · 2004
1 sentence

2017Co. v. Lopez, 156 S.W.3d 550 , 557 n.7 (Tex. 2004) (“The internal affairs doctrine is a conflict of laws principle which recognizes that only one State should have the authority to regulate a corporation’s internal affairs— matters peculiar to the relationships among or between the corporation and its current officers, directors, and shareholders... .”) (quoting Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982)); In re Crown Castle Int’l Corp., 247 S.W.3d at 354 ; see also In re Skyport Glob.

12017–2017
In Re Crown Castle International Corp. green
texapp · 2008
1 sentence

2017Co. v. Lopez, 156 S.W.3d 550 , 557 n.7 (Tex. 2004) (“The internal affairs doctrine is a conflict of laws principle which recognizes that only one State should have the authority to regulate a corporation’s internal affairs— matters peculiar to the relationships among or between the corporation and its current officers, directors, and shareholders... .”) (quoting Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982)); In re Crown Castle Int’l Corp., 247 S.W.3d at 354 ; see also In re Skyport Glob.

12017–2017
cluster 447550 green
ca5 · 1985
1 sentence

2012See Ensco, 311 S.W.3d at 928 . 15 Nicaraguan citizens allegedly injured in Nicaragua aboard vessels owned by American companies); Ali v. The Offshore Co., 753 F.2d 1327 , 1331–32 (5th Cir. 1985) (holding that the law of Trinidad applied to wrongful-death claims brought by widows of deceased citizens of Trinidad who died in the territorial waters of Trinidad aboard a drilling vessel owned by a Liberian company, an affiliate of various American companies who also were sued), overruled on other grounds by In re Air Crash Disaster Near New Orleans, La.

12012–2012
Mastrobuono v. Shearson Lehman Hutton, Inc. green
scotus · 1995
2 sentences

1999Mastrobuono v. Shearson Lehman Hutton, Inc., 514 U.S. 52, 59-60 , 115 S.Ct. 1212 , 131 L.Ed.2d 76 (1995) (the choice-of-law provision, if read in isolation, may reasonably be read as merely a substitute for the conflict-of laws analysis that otherwise would determine what law to apply to disputes); Porter Hayden Co. v. Century Indem.

1999Mastrobuono v. Shearson Lehman Hutton, Inc., 514 U.S. 52, 59-60 , 115 S.Ct. 1212 , 131 L.Ed.2d 76 (1995) (the choice-of-law provision, if read in isolation, may reasonably be read as merely a substitute for the conflict-of laws analysis that otherwise would determine what law to apply to disputes); Porter Hayden Co. v. Century Indem.

11999–1999
Porter Hayden Company v. Century Indemnity Company green
ca4 · 1998
1 sentence

1999Co., 136 F.3d 380 , 383 n. 5 (4th Cir.1998) (stating in connection with a similar provision that "this may well be the best reading of the provision, since choice-of-law provisions typically embody the parties' choice of one state’s laws over another’s, rather than express a preference between federal and state law”).

11999–1999
Vickers v. Faubion green
texapp · 1920
1 sentence

1971See, =.q., Louahran v. Loushran, 292 U.S. 216 , a. denied, 292 U.S. 615 (1934): Vickers v. Faubion, 224 S.W. 803 (Tex.Civ,App. 1920, no writ).

11971–1971
Richards v. United States green
scotus · 1962
2 sentences

1968In Richards v. United States, 369 U.S. 1 , 82 S.Ct. 585 , 7 L.Ed.2d 492 (1962), the Court said: “Our view of a State’s power to adopt an appropriate conflict-of-laws doctrine in a situation touching more than one place has been indicated by our discussion in Part III of this opinion.

1968In Richards v. United States, 369 U.S. 1 , 82 S.Ct. 585 , 7 L.Ed.2d 492 (1962), the Court said: “Our view of a State’s power to adopt an appropriate conflict-of-laws doctrine in a situation touching more than one place has been indicated by our discussion in Part III of this opinion.

11968–1968
Marilyn W. Pearson, as Administratrix of the Goods, Chattels and Credits of John S. Pearson, Deceased v. Northeast Airlines, Inc. green
ca2 · 1962
2 sentences

1968Where more than one State has sufficiently substantial contact with the activity in question, the forum State, by analysis of the interests possessed by the States involved, could constitutionally apply to the decision of the case the law of one or another state having such an interest in the multistate activity. * * *" See also Pearson v. Northeast Airlines, Inc., 309 F.2d 553 , 92 A.L.R.2d 1162 (2d Cir. 1962): "We do hold, however, that a state with substantial ties to a transaction in dispute has a legitimate constitutional interest in the application of its own rules of law. * * *" We have

1968Where more than one State has sufficiently substantial contact with the activity in question, the forum State, by analysis of the interests possessed by the States involved, could constitutionally apply to the decision of the case the law of one or another state having such an interest in the multistate activity. * * * a See also Pearson v. Northeast Airlines, Inc., 309 F.2d 553 , 92 A.L.R.2d 1162 (2d Cir. 1962) : “We do hold, however, that a state with substantial ties to a transaction in dispute has a legitimate constitutional interest in the application of its own rules of law. * * * ” We h

11968–1968

Where else courts name it

CA 25 (1943–2022) TX 22 (1968–2024) NY 16 (1948–2025) PA 15 (1937–2020) IL 14 (1964–2019) MD 13 (1968–2007) NC 13 (1990–2026) DE 13 (2012–2026) WA 12 (1994–2017) LA 7 (1972–2015) CT 7 (1991–2019) NJ 6 (1972–2025) GA 6 (1975–2017) FL 5 (1980–2017) WV 4 (1988–1993) OH 4 (1983–2024) MN 3 (1973–2019) RI 3 (1997–2006) AZ 3 (1972–2016) DC 3 (1989–2024) WY 2 (2014–2017) MA 2 (1985–2008) AL 2 (1986–2013) NE 2 (2006–2017) MT 2 (2020–2025) WI 2 (1990–2003) MS 2 (2015–2023)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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