USA – NEW JERSEY Trends and Developments Contributed by: William (Bill) Wilson and Craig R. Rygiel, Mound Cotton Wollan & Greengrass
law and, consequently, a choice-of-law analysis was necessary. New Jersey courts have long since rejected the lex loci contractus rule in favour of “a more flexible approach that focuses on the state that has the most significant connections with the parties and the transaction” ( Gil - bert Spruance Co. v Pa. Mfrs.’ Ass’n Ins. Co. , 629 A.2d 885, 888 (N.J. 1993)). The Appellate Division conclud- ed that the trial court correctly applied New York law because “New York has a clear interest in protecting the expectations of insured policyholders who are citi- zens of New York regarding homeowners insurance policies covering property and people located in New York” (id at *7). The court further concluded that “New York also has an interest in procuring predictable and uniform results for insurance-coverage claims made under those policies” (id). According to the court, “[t]hat the punch was thrown in New Jersey doesn’t diminish those interests” (id).
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