The Duke and Duchess of Arion were Spanish nationals and domiciliaries. During a period of domestic turbulence in Spain, they placed money and securities in New York banks for safekeeping. In establishing joint and separate accounts, they signed paperwork supplied by the banks in which they agreed that New York survivorship law would apply to their accounts. They never visited New York and did not execute the depository agreements there. The Duke died in 1957. The Duchess died in 1959. The value of the property deposited in New York during their marriage was approximately $2,275,000. Under New York law, the property was considered community property that went, in its entirety, to the Duchess upon her husband’s death. Under Spanish law, community property could not be transferred in its entirety to a surviving spouse. Instead, the surviving spouse was entitled only to half; other heirs of the deceased spouse were entitled to most or all of the other half. Inzer Wyatt (plaintiff), an administrator of the Duke, sued Logan Fulrath (defendant), executor of the Duchess’s will, in a New York court, claiming title to half of the New York property.