Williams v. North Carolina

In Williams v. North Carolina (1945) 325 U.S. 226, a man and a woman who were married to others and living in North Carolina went to Nevada to obtain divorces from their respective spouses and to marry each other. When they returned to North Carolina after six weeks in Nevada and established residence together, they were arrested for bigamy because North Carolina did not recognize the Nevada divorce. The United States Supreme Court explained that "a judgment in one State is conclusive upon the merits in every other State, but only if the court of the first State had power to pass on the merits--had jurisdiction, that is, to render the judgment." ( Williams v. North Carolina, supra, 325 U.S. at p. 229 165 S. Ct. at p. 1095.) The court held that, because the parties lived in North Carolina during the events in question (except for the six-week period in which the parties were in Nevada to obtain their divorces), "North Carolina was entitled to find, as she did, that they did not acquire domiciles in Nevada and that the Nevada court was therefore without power to liberate the petitioners from amenability to the laws of North Carolina governing domestic relations." ( Id. at p. 239 65 S. Ct. at p. 1099.)