Allstate Insurance Co. v. Hague

Facts

Ralph Hague was killed when the motorcycle he was a passenger on was struck from behind by a car. The accident occurred in Wisconsin. Ralph and the operators of both vehicles were residents of Wisconsin. Ralph was employed for a company in Red Wing, Minnesota for 15 years before he died, and commuted daily from Wisconsin to Red Wing. Neither the operator of the motorcycle nor the operator of the car had valid insurance. Ralph, however, held a policy issued by Defendant, Allstate Insurance Co. (Allstate), that covered three cars. His policy included an uninsured motorist clause that insured him against loss incurred from accidents with uninsured motorists. This coverage was limited to $15,000.00 for each automobile.

After the accident but prior to the initiation of the present lawsuit, Plaintiff, Ralph Hague’s widow, married a Minnesota resident and established residence in Minnesota. At the same time, she was appointed to be the personal representative of Ralph’s estate. Following her appointment, Ralph’s widow brought suit against Allstate in Minnesota state court, arguing that under Minnesota law, the $15,000.00 uninsured motorist coverage on each of Ralph’s cars could be stacked to provide a total coverage of $45,000.00. Allstate argued that the issue of whether the coverage could be stacked should be determined by Wisconsin law because the policy was delivered in Wisconsin, the accident occurred in Wisconsin, and the people involved in the accident were all residents of Wisconsin.

The trial court decided in favor of Ralph’s widow, finding that that Minnesota’s choice of law rules required the application of Minnesota’s law because Wisconsin’s law was contrary to the public policy of Minnesota. The Minnesota Supreme Court affirmed the trial court’s decision, finding that, under the “better rule” approach, Minnesota law should govern the issues of the case. The U.S. Supreme Court granted Allstate’s petition for certiorari.