More on Heath Ledger - the importance of domicile

Professors Grossman and Gans have written an interesting article for Findlaw regarding a key issue in the Heath Ledger estate.  Ledger had a child, Matilda, who was born after he executed a will in Australia, his home country. The issue of how to treat an after-born child varies from state to state and, in this case, country to country.  How to determine which state or country's law applies?  That typically turns on the issue of where the decedent was domiciled.   Ledger was living in New York at the time of his death.  However, his "home base" in the US appeared to be in Los Angeles.  And he was a citizen of Australia, where his will was executed. That will be a tricky knot for the court(s) to untangle. Domicile is also an important concept under Texas law and often is an issue in Texas trust and estate litigation.