Thank You For Submiting Feedback!
Court of Appeals of New York
September 10, 2015, Argued; December 15, 2015, Decided
[**918] [*468] [***22] Stein, J.
In IRB-Brasil Resseguros, S.A. v Inepar Invs., S.A. (20 NY3d 310, 982 NE2d 609, 958 NYS2d 689 , cert denied 569 U.S. ___, 133 S Ct 2396, 185 L Ed 2d 1105 ), this Court held that,] where parties include a New York choice-of-law clause in a contract, such a provision demonstrates the parties' intent that courts not conduct a conflict-of-laws analysis (see id. at 312). We now extend that holding to contracts that do not fall under General Obligations Law § 5-1401, and clarify that this rule obviates the application of both common-law conflict-of-laws principles and statutory choice-of-law directives, unless the parties expressly indicate otherwise.
Plaintiff Ministers and Missionaries Benefit Board (MMBB) is a New York not-for-profit corporation, based in New York County, that administers a retirement plan and a death benefit plan for certain ministers and missionaries. Decedent Clark Flesher was a minister enrolled in both plans. He named his then-wife, defendant LeAnn Snow, as his primary beneficiary and her father, defendant Leon Snow, as the contingent beneficiary. Both [****2] plans state that they "shall be governed by and construed in accordance with the laws of the State of New York."
Flesher and LeAnn Snow divorced in 2008. Flesher moved to Colorado in 2010 and died there in 2011. A Colorado court has apparently admitted his will to probate, naming his sister, defendant [*469] Michele Arnoldy, as personal representative of the estate. Despite the divorce, Flesher never changed his beneficiary designations under the MMBB plans. Because MMBB was unsure to whom the plan benefits should be paid after Flesher's death, it commenced a federal interpleader action against Flesher's Estate, Arnoldy (individually and as personal representative of the Estate), LeAnn Snow and Leon Snow.1
The United States District Court for the Southern District of New York (Griesa, J.) allowed MMBB to post a bond and be released from the case, with the obligation to pay the benefits as the court directs. Arnoldy and the Estate moved [****3] for summary judgment, and the Snows cross-moved for summary judgment. The District Court (Forrest, J.) denied the Snows' motion, granted the motion of Arnoldy and the Estate and directed MMBB to pay the disputed funds to Arnoldy, as representative of the Estate (2014 US Dist LEXIS 37822, 2014 WL 1116846 [SD NY, Mar. 18, 2014, No. 11 Civ 9495(KBF)]). In making that determination, the District Court reasoned that: (1) the parties agreed that the relevant choice-of-law rules are the rules of New York, as the forum state; (2) the disputed funds constitute personal property; (3) under EPTL 3-5.1 (b) (2), revocation of a disposition of personal property, where such property is not disposed of by a will, is determined by [***23] [**919] the law of the state where the decedent was domiciled at the time of death; (4) Flesher was domiciled in Colorado at the time of his death, so Colorado law applied; and (5) Colorado's revocation law terminated any claims to the plans by both Snows (i.e., the former spouse and her relatives) when Flesher and LeAnn Snow were divorced.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
26 N.Y.3d 466 *; 45 N.E.3d 917 **; 25 N.Y.S.3d 21 ***; 2015 N.Y. LEXIS 3865 ****; 2015 NY Slip Op 09186
 The Ministers and Missionaries Benefit Board, Interpleader Plaintiff, v Leon Snow et al., Appellants. Estate of Clark Flesher et al., Respondents.
Subsequent History: Rehearing denied by Ministers & Missionaries Ben. Bd. v Snow, 26 NY3d 1136, 2016 N.Y. LEXIS 229, 27 NYS3d 499, 47 NE3d 779 (N.Y., Feb. 23, 2016)
Prior History: Proceeding, pursuant to NY Constitution, article VI, § 3 (b) (9) and Rules of the Court of Appeals (22 NYCRR) § 500.27, to review questions certified to the New York State Court of Appeals by the United States Court of Appeals for the Second Circuit. The following questions were certified by the United States Court of Appeals and accepted by the New York State Court of Appeals: "(1) Whether a governing-law provision that states that the contract will be governed by and construed in accordance with the laws of the State of New York, in a contract not consummated pursuant to New York General Obligations Law section 5-1401, requires the application of New York Estates, Powers & Trusts Law section 3-5.1(b)(2), a New York statute that may, in turn, require application of the law of another state? (2) If so, whether a person's entitlement to proceeds under a death benefit or retirement plan, paid upon the death of the person making the designation, constitutes 'personal property . . . not disposed of by will' within the meaning of New York Estates, Powers & Trusts Law section 3-5.1(b)(2)?"
Ministers & Missionaries Benefit Bd. v Snow, 780 F3d 150, 2015 U.S. App. LEXIS 3537 (2d Cir. N.Y., 2015)
Disposition: Following certification of questions by the United States Court of Appeals for the Second Circuit and acceptance of the questions by this Court pursuant to section 500.27 of this Court's Rules of Practice, first certified question answered in the negative and second certified question not answered as academic.
choice-of-law, parties, substantive law, common-law, personal property, conflict-of-laws, principles, contracts, state law, plans, benefit plan, domiciled, beneficiary designation, designation, directive, disposed, certified question, contractual, divorce, courts, the will, waived, death benefit, governing-law, testamentary, provisions, revocation, questions, benefits, rights
Business & Corporate Compliance, Contract Conditions & Provisions, Contracts Law, Contract Conditions & Provisions, Civil Procedure, Preliminary Considerations, Federal & State Interrelationships, Choice of Law, Governments, Courts, Common Law, Contracts Law, Contract Interpretation, Intent, Estate, Gift & Trust Law, Estate Administration, Intestate Succession, Wills, Revocation of Wills