Washington Law Review


Twenty years ago an analysis of choice of law principles in the state of Washington concluded with the following observation: "The evolutionary process has finally begun in Washington. It will be a long time in developing. The limitations on that development are only those imposed by the ingenuity, insights and degree of in-depth research and work of counsel and the court."' Much has happened in the twenty years since that statement was made. On the national level, the United States Supreme Court has for the most part withdrawn from the scene and has imposed little control upon the states in the sense of constitutional limitations. Indeed, the states are now almost totally free to devise their own choice of law doctrines. The result is much diversity between states with each independently developing its own choice of law principles. Washington now has its own unique methodology. This article will discuss the developments of the past twenty years. The discussion will include an analysis of what the Washington courts have said and actually done and an evaluation of problems still to be resolved.

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