Which states have specific statutes or court rulings addressing foreign or religious marriage and inheritance practices?

1. How courts in the U.S. approach foreign religious rules — cautious reference, not wholesale adoption

U.S. cases reveal a consistent theme: judges may consider foreign or religious law as background but will not enforce provisions that conflict with American public-policy principles or statutory norms. Sources document a New Jersey case where a judge’s initial decision invoking Islamic law was overturned, illustrating that U.S. courts will permit reference to sharia or other foreign norms only when precedent and domestic law allow it; courts refuse to divide estates by sharia if that would contravene state probate law or federal protections ^{[1] [4]}. Legal guides and practice notes emphasize estate-planning pitfalls for non‑U.S. citizen spouses—New York is singled out for specific intestacy complications—and stress that foreign prenuptial agreements and wills may lack effect in U.S. courts unless they meet local formalities; this underscores that state law, not foreign religious law, typically controls inheritance outcomes in the United States ^{[5] [6]}.

2. National systems that explicitly allocate family status to religious courts — clear statutory frameworks abroad

By contrast, several national jurisdictions have statutory or constitutional structures that explicitly allocate marriage, divorce and inheritance to religious courts or personal laws, producing predictable, religion-specific outcomes. Examples include Kuwait’s 1984 Personal Status Law and Bahrain’s Family Law No. 19 of 2017, which create parallel tracks for Sunni and Shiʿi citizens; Lebanon’s confessional system recognizes 18 religious communities, each with its own courts controlling marriage and inheritance; and various South Asian jurisdictions apply Muslim personal law or allow conversion to invoke different succession regimes. These statutes and court rulings show that when a state commits by law to religious personal status systems, courts apply those frameworks directly, often raising complex questions about equality and gendered rights ^{[2] [7]}.

3. Judicial checks on religious rules — protecting secular public policy and vulnerable parties

Multiple sources show courts acting to reconcile religious practices with secular protections, frequently rejecting enforcement of religious agreements that would harm parties or contravene equal-protection norms. Canadian and U.S. courts have drawn lines between belief and practice, enforcing religious freedom for belief while restricting practices that harm rights of others; cases such as Reynolds v. United States are invoked to justify limiting religiously motivated practices that conflict with civil law. Jurisdictions have struck down or limited applications of polygyny, religiously discriminatory inheritance, or conversion-for-convenience schemes when courts determine personal law use undermines fundamental rights or the sincerity of conversion ^{[7] [2] [1]}.

4. Practical reality for cross-border families — estate planning disciplines and state-by-state variability

Practitioners emphasize that estate planning for international or religiously governed couples must be bespoke, because documentation valid abroad often fails state formalities in the U.S., and intestacy rules vary widely. Recent guides stress that trusts, wills, and marital agreements should be tailored to each relevant jurisdiction and that U.S. states—exemplified by New York—present specific hazards for noncitizen spouses. The practical takeaway is not that certain U.S. states uniformly apply foreign religious law, but that U.S. courts will evaluate foreign-religious claims against domestic probate statutes and public policy, producing uneven outcomes across states and cases depending on local rules and judicial precedent ^{[5] [6] [3]}.

5. Where scholarship and litigation point to reform or clarifying statutes — contested agendas and rights debates

Legal scholarship and comparative case studies reveal active debate over whether to codify clearer rules for when and how foreign or religious marital and inheritance norms should be recognized. Advocates for religious accommodation argue for predictability and respect for pluralism; critics warn of gender inequality and forum-shopping through conversion or foreign marriages. Sources describing conversion-for-convenience litigation and court refusals to enforce religious duties indicate courts are already policing abusive uses of personal law, while national legislatures in some countries have adopted statutes to formalize plural regimes—demonstrating competing agendas between religious autonomy and uniform civil protections ^{[2] [8]}.

6. Bottom line for identifying “which states” — no single list; look to case law and national statutes

The reviewed materials show there is no concise list of U.S. states that uniformly enforce foreign or religious marriage and inheritance rules; instead, outcomes depend on state probate statutes, evidentiary formalities, and judicial willingness to admit foreign law as interpretive context. Internationally, several countries expressly regulate personal status through religion-specific statutes or religious courts (Kuwait, Bahrain, Lebanon, plus varied South Asian examples), so the best method to identify applicable rules is jurisdiction-by-jurisdiction research into statutes and recent appellate decisions rather than relying on generalized assertions ^{[1] [2] [3]}.