Does a contract of guaranty create a secondary liability rather than a primary liability?

A contract of guaranty is an obligation to answer for the debt of another. A guaranty creates a secondary, rather than a primary, liability because it relates

[151 BR 683]

to the independent obligation of the primary obligor and is contingent on the obligor's default. See, generally, Michaels v. Chemical Bank, 110 Misc.2d 74, 441 N.Y.S.2d 638 (1981); 63 N.Y.Jur., 2d 1, et seq. In the guaranty relevant here, the parties stipulated that Massachusetts law governs any and all disputes arising from the guaranty agreement.