When there is more than one state, or more than one jurisdiction (state court, federal court) with a significant relationship to the parties and circumstances involved in a lawsuit or dispute, the question may arise as to which state or jurisdiction’s laws will govern the lawsuit or dispute. The body of law that determines what law governs a dispute is called conflict of laws and consists of legal principles courts use to determine which state or jurisdiction’s law applies—unless the parties to a dispute have agreed (usually in a contract) on what law will apply.

In New York, as in other states, the issue of which jurisdiction's laws apply to a legal dispute is governed by the principles of 'conflict of laws' or 'choice of law.' These principles are designed to resolve questions of which state or country's law should be applied when a legal dispute has connections to more than one jurisdiction. New York courts will consider various factors, such as the places of contracting, negotiation, performance, the location of the subject matter of the dispute, and the domicile or place of business of the parties involved. The courts aim to apply the law of the jurisdiction that has the most significant relationship to the dispute and the parties. In contractual situations, New York courts will generally honor a choice of law provision specified in the contract, as long as the chosen law bears a reasonable relationship to the parties or the transaction and is not contrary to the fundamental policy of a state with a materially greater interest. When no such provision exists, New York courts will conduct a choice of law analysis to determine which jurisdiction's substantive law should govern the dispute. It's important to note that choice of law rules can be complex, and the outcome can significantly affect the rights and obligations of the parties involved. Therefore, consulting with an attorney who is knowledgeable in conflict of laws is advisable when dealing with multi-jurisdictional legal issues.