In IRB-Brasil Resseguros v. Inepar Investments, the New York Court of Appeals held that a court interpreting a contract where the parties have chosen New York law, pursuant to New York General Obligations Law section 5-1401, should apply New York substantive law to the contract. New York substantive law applies regardless of whether the parties explicitly excluded New York conflict-of-laws rules and even if a traditional conflict of laws analysis would result in the application of another jurisdiction’s substantive law.View full memo, "Common Sense Trumps Extra Words in Governing Law Clause"
