Burr v. Beckler

While traveling in Florida, Ednah Beckler (defendant), at her husband's urging, executed and mailed to Chicago a promissory note in favor of Shelton Burr (plaintiff), pledging Chicago real property as collateral. When Beckler defaulted, Burr sued in Illinois to foreclose on the deed of trust; Beckler argued the note was invalid because, under Florida's coverture law, married women lacked legal capacity to execute such contracts. The trial court agreed and dismissed the case, but the appellate court reversed, reasoning Illinois law governed because the collateral property was located in Illinois. The Illinois Supreme Court reviewed.