The Supreme Court today denied certiorari in Midland Funding v. Madden. Although the denial leaves the Second Circuit's May 2015 decision in place, it does not signal the Supreme Court's view of the correctness of that ruling or of the ultimate outcome of the case. The parties in Madden will now proceed in the district court to litigate important state law issues like the common law valid-when-made doctrine and the enforceability of the choice-of-law provisions under New York law, which we discussed in greater detail in our November 2015 case update. It also remains to be seen whether courts outside of the Second Circuit will follow the Madden decision, particularly in light of the U.S. Government's position that Madden was wrongly decided (discussed here). Even within the Second Circuit, the courts will now have to grapple with how to construe Madden and whether to extend the decision beyond the context addressed by the Second Circuit—the sale of defaulted-debt.