Watts v. Swiss Bank Corp.

Aristide Lanari, an Italian citizen, and his second wife, Roberta Maccoun, an American citizen, were living in France when Lanari died. Before his death, Lanari and Maccoun opened an account at Swiss Bank Corporation (defendant) in its New York office. After Lanari died, Maccoun asked the bank to turn over the account assets to her as the surviving joint tenant on the account. However, Lanari had a daughter from his first marriage, Maria Elena Meyer (defendant). Meyer had previously filed a declaratory-relief action in France that sought the application of French law. Maccoun died during the French proceedings and was replaced by her executors, led by Sewell Watts (plaintiff), acting on behalf of her three sisters, who were her heirs. The French tribunal ruled that French law applied, limiting Maccoun to a maximum of one-fourth of the estate, with the remainder owed to Meyer. The ruling covered not only assets in France but also assets in other jurisdictions, including the United States. The French tribunal noted that the assets held in other jurisdictions were an attempt to avoid the effect of French law. Meyer opposed Maccoun’s attempt to take the Swiss Bank account funds, arguing that the decision of the French court was binding under the doctrine of res judicata. The United States trial court agreed with Meyer. Maccoun appealed.