Cardon v. Cotton Lane Holdings, Inc

In Cardon v. Cotton Lane Holdings, Inc., 173 Ariz. 203, 207, 841 P.2d 198, 202 (1992), the supreme court of Arizona held that a California choice-of-law provision in the parties' contract documents effectively precluded a creditor's action under Arizona law for a deficiency judgment following a nonjudicial trustee's sale pursuant to a deed of trust. Despite the contractual choice-of-law provision, the court in Cardon applied Restatement 187 to determine whether the parties' choice of California law was "valid and effective." 173 Ariz. at 208, 841 P.2d at 203.