Gray Gray 87 NH. 82 (1934) Facts: ‘The husband and wife [Mr and Ms. Gray) are domiciled in New Hampshire, a state which permits the wife to sue the husband for, ‘personal injuries caused by the husband's negligence. While @ ‘passenger in an automobile driven by the husband in Maine, the wite 's injured asa result of the husband's negligence. Under Maine law spouses are barred from maintaining an action against each other ‘Thus Ms, Gray sued Mr, Gray in New Hamsphire. Issue/s: WON in conflicts airising from a tort, lex loci governs (the law of the country in which a transaction is performed, a tort is committed, ora property is situated.) YES Hela: The effect ofthe prohibition in Maine isto divest the W of any cause of action against H. f there sa conflict between lex for (the law of ‘the country in which an action is brought) and lex oc, lex loci governs in torts in respect to the legal effect and incidents ofthe act. The status as spouses is datermined by New Hampshice law but the incidents ofthat status is governed by the law of the place ofthe transaction (Maine)