Ministers And Missionaries Benefit Board v. Snow

45 N.E.3d 917 (2015)

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Nature of the Case

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Facts

P is a New York not-for-profit corporation 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, D, as his primary beneficiary and her father, Leon, as the contingent beneficiary. Both plans state that they 'shall be governed by and construed in accordance with the laws of the State of New York.' Flesher and D divorced in 2008. Flesher moved to Colorado in 2010 and died there in 2011. A Colorado court has admitted his will to probate, naming his sister, Michele Arnoldy (D), as personal representative of the estate. Flesher never changed his beneficiary designations under the P plans. P was unsure to whom the plan benefits should be paid after Flesher's death. P commenced a federal interpleader action against Flesher's Estate, Arnoldy (individually and as personal representative of the Estate), D, and Leon Snow. P posted a bond and was released from the case. Arnoldy and the Estate moved for summary judgment and the Snows cross-moved for summary judgment. The District Court denied the Snows' motion, granted the motion of Arnoldy and the Estate, and directed P to pay the disputed funds to Arnoldy, as representative of the Estate. The parties agreed that the relevant choice-of-law rules are the rules of New York, as the forum state. 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 the law of the state where the decedent was domiciled at the time of death. Flesher was domiciled in Colorado at the time of his death, so Colorado law applied and its revocation law terminated any claims to the plans by both Snows when Flesher and D were divorced. D appealed. The court certified two questions one of which is relevant: 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?