Donlann v. MacGurn
In Donlann v. MacGurn, 203 Ariz. 380, 55 P.3d 74 (App. 2002) a marriage was performed in Jalisco, Mexico. Both parties were residents of Arizona. Applying the general rule, the validity of the marriage would then turn on Mexican law.
The marriage did not comply with Mexican law because "the person who signed the marriage certificate did not perform the ceremony." Id. at 383, P14, 55 P.3d at 77.
Because the parties in good faith believed that a valid ceremony had been performed, and in such circumstances Arizona law would recognize the ceremony, the court recognized the marriage. Id. at 382-84, 387, PP6, 15-20, 38, 55 P.3d at 76-78, 81.
Donlann, however, also pointed to the justified expectations of the parties and the fact that the most significant relationship of the parties was to the state of Arizona. Id. at 383-84, PP15-20, 55 P.3d at 77-78.
It found that a marriage that was "technically flawed" in the jurisdiction where performed would nonetheless be recognized in Arizona as it was consistent with Arizona law. Id. at 384, P15, 55 P.3d at 78.
Thus, Donlann did not employ the "most significant relationship" consideration to give effect to a marriage that would otherwise not be recognized in Arizona; it considered the relationship of the parties to the forum to explain why it was giving effect to a marriage that was valid in Arizona but not in the place where performed. Id.