New York Law Review

Tag: Federal-State Law

  • Curtiss-Wright Flight Systems, Inc. v. Bresson, 88 N.Y.2d 514 (1996): Declining Certification Due to Rarity and Federal-State Law Interplay

    Curtiss-Wright Flight Systems, Inc. v. Bresson, 88 N.Y.2d 514 (1996)

    A state’s highest court may decline to answer a certified question from a federal court when the issue is unlikely to recur, the parties provide limited assistance, and the issue involves unsettled interplay between federal and state law.

    Summary

    In this case, the New York Court of Appeals declined to answer a certified question from the Second Circuit regarding ERISA benefits distribution to a second spouse in a void marriage. The court exercised its discretion under section 500.17 of the Rules of the Court of Appeals. The court reasoned that the issue’s likely rarity, the pro se status of one defendant, the other defendant’s non-submission of a brief, the stakeholder status of the plaintiffs, and the unsettled interplay between federal and state law made it inappropriate for the court to answer the certified question. The court believed these factors would limit the assistance it could receive in deciding an issue with potentially broad precedential significance.

    Facts

    The United States Court of Appeals for the Second Circuit certified a question to the New York Court of Appeals. The case involved a dispute over death benefits under the Employee Retirement Income Security Act (ERISA). The specific question concerned the rights of a second spouse whose marriage was void due to a prior, undissolved marriage of the deceased. The second marriage was the result of a formal ceremony, undertaken in good faith, and continued until the spouse’s death.

    Procedural History

    The Second Circuit certified the question to the New York Court of Appeals pursuant to section 500.17 of the Rules of the Court of Appeals (22 NYCRR 500.17) after hearing the case at the appellate level. The New York Court of Appeals then considered whether to accept the certified question.

    Issue(s)

    Whether the New York Court of Appeals should accept a certified question from the Second Circuit regarding the distribution of ERISA benefits to a second spouse whose marriage was void due to a prior, undissolved marriage.

    Holding

    No, because the issue’s likely rarity, the limited assistance from the parties involved, and the unsettled interplay between federal and state law made it more appropriate for resolution in the first instance by the Federal courts.

    Court’s Reasoning

    The court declined to accept the certified question based on several factors. First, the court agreed with the Second Circuit’s assessment of the likely rarity of the issue. Second, the court noted that the defendant-appellant appeared pro se, the defendant-respondent had not submitted a brief, and the plaintiffs-respondents were mere stakeholders. This meant that the court could expect only limited assistance from the parties in deciding the issue, which may have precedential significance beyond the ERISA context. Finally, the court emphasized the unsettled interplay between federal and state law in interpreting issues of statutory construction under ERISA. The court concluded that this issue may be more appropriately resolved by the Federal courts in the first instance. The court stated, “the interplay between Federal and State law in interpreting issues of statutory construction under ERISA is as yet not fully settled. This issue may thus be more appropriate for resolution in the first instance by the Federal courts.”