Vanderbilt v. Vanderbilt

In Vanderbilt v. Vanderbilt, 354 U.S. 416 (1957), the parties were married and lived in California, where they separated in 1952. The wife moved to New York, and in 1953, the husband received a decree of divorce in Nevada which provided that both husband and wife were "freed and released from the bonds of matrimony and all duties and obligations thereof . . . ." The wife was not served with process in Nevada, did not appear in the proceedings, and it was agreed that the Nevada courts could not constitutionally assert personal jurisdiction over the wife. In 1954, the wife brought suit in New York seeking alimony. The New York court found the Nevada divorce decree to be valid and enforceable insofar as it dissolved the marriage, under the Full Faith and Credit Clause (Article IV, section 1) of the United States Constitution. However, the New York court directed the husband to make support payments to the wife. The husband appealed, arguing that the Nevada divorce decree had terminated the wife's right to seek any relief under any other state's laws. On appeal by the husband, the United States Supreme Court affirmed New York's award of alimony to the wife. The Court concluded that because Nevada did not have personal jurisdiction over the wife, the Nevada courts had no power to extinguish any right to financial support that the wife had under the law of New York. The Court stated that: Since the wife was not subject to its jurisdiction, the Nevada divorce court had no power to extinguish any right which she had under the law of New York to financial support from her husband. It has long been the constitutional rule that a court cannot adjudicate a personal claim or obligation unless it has jurisdiction over the person of the defendant. Here the Nevada divorce court was as powerless to cut off the wife's support right as it would have been to order the husband to pay alimony if the wife had brought the divorce action and he had not been subject to the divorce court's jurisdiction. Therefore, the Nevada decree, to the extent it purported to affect the wife's right to support, was void and the Full Faith and Credit Clause did not obligate New York to give it recognition. (Vanderbilt, 354 U.S. at 418-19, 77 S. Ct. at 1362-63, 1 L. Ed. 2d at 1459.)