In Illinois, "choice of law" refers to the process by which a court determines which jurisdiction’s laws govern the legal issues in a case.
Illinois uses the "most significant relationship" approach from the Restatement (Second) of Conflict of Laws to determine the applicable law in tort cases, considering factors like where the injury occurred and the parties' connections to the jurisdictions involved.
Illinois follows the internal affairs doctrine, which means that the law governing a corporation’s internal affairs is the law of the state where the corporation is incorporated.
Illinois courts typically reject renvoi, meaning they apply only the substantive law of the other jurisdiction, not its choice-of-law rules.
For personal property disputes, Illinois typically applies the law of the state where the property is physically located.
