marriage has nothing to do with England. Therefore, two thresholds of English Public Policy exist in limiting lex causae, one which applies regardless and a second, higher threshold which only applies if issues have a real and substantial connection with England. U.S. Method Comparatively, in the US, the New York Court of Appeals set a national trend in Babcock v. Jackson, 240 N.E.2d 279 (N.Y. 1963), which abandoned the lex loci delicti rule completely. Most jurisdictions have not been so radical and preferred to retain the framework of categories and choice of law rules but left public policy in place, as an avoidance device. That exception provides that states will not apply any foreign law that offends the deeply held principles of the forum state's legal system. For example, it would be considered improper to give enforcement to a law that defined the status of a person as a slave or as in the possession of another, such as for the purposes of sexual exploitation. In cases involving alleged immorality or injustice, that rule has been criticised as susceptible to abuse, as a court could characterise almost any statute or rule as being offensive to the public policy of their state. Less controversial are bars to any cases that would give extraterritorial effect to laws which are confiscatory, seeking to collect taxes owing in another state, or penal: laws that are designed to punish the party committing the wrong, rather than those to compensate the party that suffered loss or injury. That can sometimes lead to a fine balancing act between claims for compensatory and exemplary damages. In the US, the concept of governmental interest analysis was developed by Brainerd Currie and is preferred by many American conflicts writers. Currie focused on each state's substantive rules, rather than on a metaphorical test, for the seat of the legal relationships and assumed that governments are less interested in what happens within their territorial boundaries than in the well-being of their subjects. The methodology that he proposed relies almost entirely on the personal nexus between the litigants and the states. However, there is no single test for this nexus at an international level. Some states use the concept of domicile, others nationality, and the remainder citizenship; also, definitions of domicile vary from state to state. That methodology has thus never been accepted outside the US. Also, if the litigants are from different