Vandever v. Indus. Comm'n
In Vandever v. Indus. Comm'n, 148 Ariz. 373, 376, 714 P.2d 866, 869 (App. 1985), the parties were arguably domiciled in Arizona, yet one party contended that a common-law marriage had been entered into pursuant to the law of Colorado.
The Court expressly rejected a request to "incorporate into A.R.S. 25-112 a choice-of-law analysis that would require this court to discern which state has the most significant contacts with the marriage relationship." 148 Ariz. at 376, 714 P.2d at 869.
Though citing those portions of 283(2) that allowed for exceptions to the general rule based on strong policy considerations, the court rejected the request that it look to the state with the "most significant relationship" as the Restatement provided. Id.