Key legal question
Whether the cantonal court arbitrarily found the first matrimonial domicile and law applicable before the separation agreement
Extracted holding
The challenged factual findings were irrelevant, because the applicable law had to be determined by analogy under Art. 31 para. 3 LRDC, not by Art. 19 LRDC.
Extracted reasoning
Since the spouses had several prior domiciles abroad, their internal matrimonial relations remained governed by the law of their last foreign domicile, here Saudi Arabia; findings about an earlier U.S. domicile could not affect the outcome.