In Fall v. Eastin (1909) 215 U.S. 1, a husband and wife owned property in Nebraska when the husband filed for divorce in Washington, where the couple lived. The Washington court granted the husband a divorce, but found the Nebraska property to be the wife's separate property. Consistent with the foregoing exception, the Washington court ordered the husband to execute a deed conveying his interests in the Nebraska property to the wife. When the husband refused, the Washington court appointed a commissioner who executed the conveyance on the husband's behalf. (Fall, supra, 215 U.S. at pp. 2-4.) The wife later filed a quiet title action in Nebraska based upon the conveyance, but the Nebraska court denied her any relief because the husband had not signed the conveyance. (Fall, supra, 215 U.S. at pp. 2, 4.) The Nebraska court concluded the purported conveyance was based on a void and ineffective judgment seeking to affect title to property in another state because the Washington court ultimately carried out the conveyance through its appointed commissioner, not the husband. (Id. at pp. 5-8.) The United States Supreme Court affirmed the Nebraska decision based on the general rule prohibiting a state from making judgments or orders affecting title to property in other states. The Fall court explained the foregoing exception did not apply because the Washington court did not use its coercive powers to make the husband execute the conveyance, but rather ordered the conveyance itself by appointing a commissioner to execute the conveyance on the husband's behalf. (Id. at p. 14.)