Probate Exception. The Second Circuit has reinterpreted the probate exception, which provided that federal courts should not, in general, decide cases dealing with probate issues. The Court has held that a federal court should decline subject-matter jurisdiction only if a plaintiff seeks (1) to acheive to administer an estate, probate a will, or do any other purely probate matter or (2) to reach a res in the custody of a state court in federal court

The decision in Lefkowitz v. Bank of New York can be found here.