conflict of laws principle (Delaware) · Go Syfert
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conflict of laws principle in Delaware

13 Delaware opinions name it 3 courts 2012–2026 2 in the last five years

The cases below were cited by Delaware 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 (8)

CaseFollowedCited
Edgar v. Mite Corp.green
scotus · 1982 · cited in 8 Delaware opinions naming this issue, 2012–2026
2 sentences

2026Jan. 28, 2015). 103 See Restatement, supra, § 188 cmt. e. 104 See Edgar v. MITE Corp., 457 U.S. 624, 645 (1982) (“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 37 apply, the Delaware Forum Clause will govern, and the Partnership Agreement will receive uniform treatment.

2020The United States Supreme Court then described the internal affairs doctrine as follows: 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—because otherwise a corporation could be faced with conflicting demands.107 As applied to the Illinois law, the Court found that the internal affairs doctrine was “of little use to the State in this context” because

48
Barrett v. Stategreen
del · 2017 · cited in 2 Delaware opinions naming this issue, 2017–2021
2 sentences

2021In contrast, “[t]he modern approach indicates that the laws of the jurisdiction which had the most significant relationship to the transaction and parties would control the substantive legal questions.” Id. (citations omitted). 34 Reese, 2004 WL 1320900 , at *2. 35 Certain Underwriters at Lloyds, London v. Chemtura Corp. [hereinafter “Chemtura”], 160 A.3d 457, 465 (Del. 2017). 36 D.I. 35, at 12-13. 9 rendered should govern disputes concerning its interpretation or effect.” 37 Sullivan responds that “Richetti did not rule that the location of the divorce is a dispositive factor,” but only that

2017D (Pledge Agreement) §§ 14, 16 (“This Agreement shall be governed by and construed in accordance with the laws of the State of New York” and Charney consents to jurisdiction in New York). 74 Certain Underwriters at Lloyds, London v. Chemtura Corp., 160 A.3d 457, 464 (Del. 2017) (citation omitted) (the first of three components in choice of law analysis is “determining if the parties made an effective choice of law through their contract”). 75 Ministers & Missionaries Benefit Bd. v. Snow, 45 N.E.3d 917, 918 (N.Y. 2015), rearg. denied, 47 N.E.3d 779 (N.Y. 2016) (holding that the inclusion of a “

22
Vantagepoint Venture Partners 1996 v. Examen, Inc.green
del · 2005 · cited in 2 Delaware opinions naming this issue, 2012–2020
2 sentences

2020So too with the Non-Solicitation Provision: It applies “during the Unit Holder’s employment or service period with the 9 See Edgar v. MITE Corp., 457 U.S. 624, 645 (1982) (“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— because otherwise a corporation could be faced with conflicting demands.”) (citing Restatement, supra, § 302 cmt. b.); Salzberg v.

2020So too with the Non-Solicitation Provision: It applies “during the Unit Holder’s employment or service period with the 9 See Edgar v. MITE Corp., 457 U.S. 624, 645 (1982) (“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— because otherwise a corporation could be faced with conflicting demands.”) (citing Restatement, supra, § 302 cmt. b.); Salzberg v.

22
OSI Systems, Inc. v. Instrumentarium Corp.green
delch · 2006 · cited in 1 Delaware opinions naming this issue, 2021–2021
1 sentence

2021Since the Policies are silent on choice of law, I first “compare the laws of the competing jurisdictions to determine whether the laws actually conflict,” or would “produce different results when applied to the factors of the case.”30 Pennsylvania has a revocation-on-divorce 27 OSI Sys., Inc. v. Instrumentarium Corp., 892 A.2d 1086, 1090 (Del.

11
The Ministers and Missionaries Benefit Board v. Leon Snow v. The Estate of Clark Fleshergreen
ny · 2015 · cited in 1 Delaware opinions naming this issue, 2017–2017
1 sentence

2017D (Pledge Agreement) §§ 14, 16 (“This Agreement shall be governed by and construed in accordance with the laws of the State of New York” and Charney consents to jurisdiction in New York). 74 Certain Underwriters at Lloyds, London v. Chemtura Corp., 160 A.3d 457, 464 (Del. 2017) (citation omitted) (the first of three components in choice of law analysis is “determining if the parties made an effective choice of law through their contract”). 75 Ministers & Missionaries Benefit Bd. v. Snow, 45 N.E.3d 917, 918 (N.Y. 2015), rearg. denied, 47 N.E.3d 779 (N.Y. 2016) (holding that the inclusion of a “

11
Deuley v. DynCorp International, Inc.green
del · 2010 · cited in 1 Delaware opinions naming this issue, 2016–2016
1 sentence

2016Del. 2010) (forecasting that Delaware courts would require the existence of an actual conflict before embarking on a conflict of laws analysis)). 79 Deuley v. DynCorp Int’l., Inc., 8 A.3d 1156, 1161 (Del. 2010). 80 State Farm Gen.

11
D'ANGELO v. Petroleos Mexicanosgreen
del · 1974 · cited in 1 Delaware opinions naming this issue, 2014–2014
1 sentence

2014See D'Angelo v. Petroleos Mexicanos, 331 A.2d 388, 391-92 (Del.1974) (citing to an earlier version of the Restatement for the proposition that the act of state doctrine is similar to a conflict of laws principle: "It is ‘similar to those conflict of laws principles that direct the choice of a foreign law, or apply the principles of res judicata to foreign judgments, or give faith and credit to foreign legislation or to foreign judgments, or dismiss the proceedings on the basis of forum non conveniens.' ” (quoting Restatement (Second) of the Foreign Relations Law of the United States § 41, emts

11
CTS Corp. v. Dynamics Corp. of Americagreen
scotus · 1987 · cited in 1 Delaware opinions naming this issue, 2013–2013
2 sentences

2013See CTS Corp. v. Dynamics Corp., 481 U.S. 69, 90 , 107 S.Ct. 1637 , 95 L.Ed.2d 67 (1987) ("[A] corporation — except in the rarest situations — is organized under, and governed by, the law of a single jurisdiction, traditionally the corporate law of the State of its incorporation.”); Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982) ("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 cor

2013See CTS Corp. v. Dynamics Corp., 481 U.S. 69, 90 , 107 S.Ct. 1637 , 95 L.Ed.2d 67 (1987) ("[A] corporation — except in the rarest situations — is organized under, and governed by, the law of a single jurisdiction, traditionally the corporate law of the State of its incorporation.”); Edgar v. MITE Corp., 457 U.S. 624, 645 , 102 S.Ct. 2629 , 73 L.Ed.2d 269 (1982) ("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 cor

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
National U. Fire Ins. Co., Etc. v. Rlc Corp. green
delsuperct · 1982
1 sentence

2021In contrast, “[t]he modern approach indicates that the laws of the jurisdiction which had the most significant relationship to the transaction and parties would control the substantive legal questions.” Id. (citations omitted). 34 Reese, 2004 WL 1320900 , at *2. 35 Certain Underwriters at Lloyds, London v. Chemtura Corp. [hereinafter “Chemtura”], 160 A.3d 457, 465 (Del. 2017). 36 D.I. 35, at 12-13. 9 rendered should govern disputes concerning its interpretation or effect.” 37 Sullivan responds that “Richetti did not rule that the location of the divorce is a dispositive factor,” but only that

12021–2021
In re Koziol neutral
ny · 2016
1 sentence

2017D (Pledge Agreement) §§ 14, 16 (“This Agreement shall be governed by and construed in accordance with the laws of the State of New York” and Charney consents to jurisdiction in New York). 74 Certain Underwriters at Lloyds, London v. Chemtura Corp., 160 A.3d 457, 464 (Del. 2017) (citation omitted) (the first of three components in choice of law analysis is “determining if the parties made an effective choice of law through their contract”). 75 Ministers & Missionaries Benefit Bd. v. Snow, 45 N.E.3d 917, 918 (N.Y. 2015), rearg. denied, 47 N.E.3d 779 (N.Y. 2016) (holding that the inclusion of a “

12017–2017
State of São Paulo of Federative Republic of Brazil v. American Tobacco Co. green
del · 2007
1 sentence

2015Tobacco Co., 919 A.2d 1116 (Del. 2007)). 13 with a conflict of laws analysis.

12015–2015
Kamen v. Kemper Financial Services, Inc. green
scotus · 1991
2 sentences

2013Servs., Inc., 500 U.S. 90, 92 , 111 S.Ct. 1711 , 114 L.Ed.2d 152 (1991) (holding that in a derivative suit "the scope of the demand requirement embodies the incorporating State’s allocation of governing powers within the corporation”); Burks v. Lasker, 441 U.S. 471, 478 , 99 S.Ct. 1831 , 60 L.Ed.2d 404 (1979) ("|T]he first place one must look to determine the powers of corporate directors is in the relevant State’s corporation law.” (citations omitted)). .Joseph A. Grundfest & Kristen A. Savelle, The Brouhaha over Intra-Corporate Forum Selection Provisions: A Legal, Economic, and Political Ana

2013Servs., Inc., 500 U.S. 90, 92 , 111 S.Ct. 1711 , 114 L.Ed.2d 152 (1991) (holding that in a derivative suit "the scope of the demand requirement embodies the incorporating State’s allocation of governing powers within the corporation”); Burks v. Lasker, 441 U.S. 471, 478 , 99 S.Ct. 1831 , 60 L.Ed.2d 404 (1979) ("|T]he first place one must look to determine the powers of corporate directors is in the relevant State’s corporation law.” (citations omitted)). .Joseph A. Grundfest & Kristen A. Savelle, The Brouhaha over Intra-Corporate Forum Selection Provisions: A Legal, Economic, and Political Ana

12013–2013
Burks v. Lasker green
scotus · 1979
2 sentences

2013Servs., Inc., 500 U.S. 90, 92 , 111 S.Ct. 1711 , 114 L.Ed.2d 152 (1991) (holding that in a derivative suit "the scope of the demand requirement embodies the incorporating State’s allocation of governing powers within the corporation”); Burks v. Lasker, 441 U.S. 471, 478 , 99 S.Ct. 1831 , 60 L.Ed.2d 404 (1979) ("|T]he first place one must look to determine the powers of corporate directors is in the relevant State’s corporation law.” (citations omitted)). .Joseph A. Grundfest & Kristen A. Savelle, The Brouhaha over Intra-Corporate Forum Selection Provisions: A Legal, Economic, and Political Ana

2013Servs., Inc., 500 U.S. 90, 92 , 111 S.Ct. 1711 , 114 L.Ed.2d 152 (1991) (holding that in a derivative suit "the scope of the demand requirement embodies the incorporating State’s allocation of governing powers within the corporation”); Burks v. Lasker, 441 U.S. 471, 478 , 99 S.Ct. 1831 , 60 L.Ed.2d 404 (1979) ("|T]he first place one must look to determine the powers of corporate directors is in the relevant State’s corporation law.” (citations omitted)). .Joseph A. Grundfest & Kristen A. Savelle, The Brouhaha over Intra-Corporate Forum Selection Provisions: A Legal, Economic, and Political Ana

12013–2013

Statutes the citing opinions construe

DE § 8 Del. C. § 152 (3) DE § 8 Del. C. § 157 (3) DE § 8 Del. C. § 166 (3) DE § 8 Del. C. § 242 (3) USC § 15u.s.c.77e (3) USC § 15u.s.c.77k(a) (3) USC § 15u.s.c.77k(a)(1) (3) USC § 15u.s.c.77l(a)(1) (3) USC § 15u.s.c.77o(a) (3) USC § 15u.s.c.77v(a) (3) USC § 15u.s.c.77z (3) USC § 15u.s.c.78u (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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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