Matter of Geraghty

Kenneth and Paula Geraghty married in New York in 1986, moved to Massachusetts in 1990, then to New Hampshire in 2008. Paula petitioned for divorce in New Hampshire in 2013; Kenneth sought an annulment for fraud, alleging Paula had concealed prior prostitution and drug use, and argued New York law should govern. The trial court applied New Hampshire law and granted the divorce.

Whether, in determining which state's law governs a divorce proceeding, a court must weigh predictability of results, orderliness among the states, simplicity of the judicial task, the forum state's governmental interests, and the forum's preference for the sounder rule of law.