choice-of-law analysis in Maine

2026As no Maine resident is a party to the action and Valmont-Olivier filed for and received workers’ compensation benefits in Massachusetts, “honoring the purposes underlying workers’ compensation has become primarily an issue of Massachusetts concern.” See id. at 27 ; see also Collins, 663 A.2d at 573 (applying Canadian damages law to an action arising out of a Maine accident, where the parties were Canadian residents and “Canada has demonstrated a profound interest in achieving a measure of uniformity in tort recovery among Canadian residents”). [¶15] For these reasons, the court did not err in

2005See Collins v. Trius, Inc., 663 A.2d 570, 573 (Me. 1995).

2024See Stenzel v. Dell, Inc., 2005 ME 37, ¶ 8 , 870 A.2d 133 (applying an agreement’s choice of law provision without conducting an independent analysis); Borden v. Paul Revere Life Ins.

2024See Stenzel v. Dell, Inc., 2005 ME 37, ¶ 8 , 870 A.2d 133 (applying an agreement’s choice of law provision without conducting an independent analysis); Borden v. Paul Revere Life Ins.

2006See id. (stating, "the internal affairs doctrine is a long-standing choice of law principle which recognizes that only one state should have the authority to regulate a corporation's internal affairs - the state of incorporation.") Moreover, many states, including Maine, have codified it.

2006See id. (stating, "the internal affairs doctrine is a long-standing choice of law principle which recognizes that only one state should have the authority to regulate a corporation's internal affairs - the state of incorporation.") Moreover, many states, including Maine, have codified it.

2005See Schroeder v. Rynel, Ltd., 1998 ME 259 , { 8, 720 A.2d 1164, 1166 .

2005See Schroeder v. Rynel, Ltd., 1998 ME 259 , { 8, 720 A.2d 1164, 1166 .

2005See also 5 306, cmt. c ("The local law of some state other than the state of incorporation is most likely to be applied in a situation where the corporation does all, or nearly all, of its business and has most of its shareholders in that other state and has little contact, apart from the fact of its incorporation, with the state of incorporation."); and Cacho v. Prince of Fundy Cruises, Ltd., 1998 ME 249 , 7 16, 722 A.2d 349, 352 (explaining that the place of incorporation is "a fact that is 'significant' in a choice of law analysis.") Here, although Caribbean does business in Maine and its s

2005See also 5 306, cmt. c ("The local law of some state other than the state of incorporation is most likely to be applied in a situation where the corporation does all, or nearly all, of its business and has most of its shareholders in that other state and has little contact, apart from the fact of its incorporation, with the state of incorporation."); and Cacho v. Prince of Fundy Cruises, Ltd., 1998 ME 249 , 7 16, 722 A.2d 349, 352 (explaining that the place of incorporation is "a fact that is 'significant' in a choice of law analysis.") Here, although Caribbean does business in Maine and its s

1998Walters, 781 F.Supp. at 814-15 . [¶ 17] Courts will examine the corporate makeup of the defendant shipowner and charterer and “ ‘look through the facade of foreign registration and incorporation to find the true ownership of the vessel’ and its operator.” Kukias, 839 F.2d at 862 (quoting Villar v. Crowley Maritime Corp., 782 F.2d 1478, 1481 (9th Cir.1986)).

1998See Kukias, 839 F.2d at 862 .

1998Walters, 781 F.Supp. at 814-15 . [¶ 17] Courts will examine the corporate makeup of the defendant shipowner and charterer and “ ‘look through the facade of foreign registration and incorporation to find the true ownership of the vessel’ and its operator.” Kukias, 839 F.2d at 862 (quoting Villar v. Crowley Maritime Corp., 782 F.2d 1478, 1481 (9th Cir.1986)).

1979Woods, supra at 891 (citations omitted).