Martha Corlett was a citizen of Canada and William Hoelker a citizen of the U.S. Before they were married the parties purchased a condominium in Vancouver. During their relationship they resided in Arizona and in Washington. The condominium was purchased with the husband’s money but it was registered in both their names. After the parties separated, the wife moved into the condominium. Both parties are claiming possession of the condominium. What law should apply to the dispute and where should the action be brought? 

How would it affect your answer to know that the husband commenced an action in the U.S. for divorce and possession of the condominium and that the wife fought and participated in the action that continued for 5 years. She never challenged the jurisdiction of that court nor claimed that B.C law should apply. Only after she lost did she bring an action in British Columbia asking that the British Columbia court apply the more friendly Family Relations Act and not enforce the Washington decision.