Wyatt v. Fulrath

The Spanish Duke and Duchess of Arion deposited roughly $2,275,000 in New York bank accounts during domestic unrest in Spain, signing bank paperwork agreeing that New York survivorship law would govern the accounts, though they never visited New York or executed the agreements there. Under New York law the property was community property passing entirely to the surviving spouse; under Spanish law the surviving spouse would get only half, with other heirs entitled to the rest. After both spouses died, Wyatt (plaintiff), the Duke's estate administrator, sued Fulrath (defendant), the Duchess's executor, claiming half the New York property under Spanish law.

Whether, where foreign parties place personal property in an American state with the intent that the property be governed by that state's law, an American forum may apply that state's law.