The Ministers and Missionaries Benefit Board, Interpleader Plaintiff v. Leon Snow, Appellants. Estate of…

Summary

The New York Court of Appeals held that a contract choice‑of‑law clause that designates New York law applies only to New York substantive law and does not incorporate New York’s statutory choice‑of‑law directive EPTL § 3‑5.1(b)(2), answering the first certified question in the negative and declining to answer the second question. Justice Abdus‑Salaam dissented, arguing both certified questions should be answered affirmatively.