Vanderbilt v. Vanderbilt – Divorce
Vanderbilt v. Vanderbilt, 354 U.S. 416, 77 S. Ct. 1360, 1 L. Ed. 2d 1456 (1957).
NATURE OF THE CASE: This family law case involved an issue of full faith and credit in the context of a divorce decree.
FACTS: Cornelius (H) and Patricia (W) Vanderbilt were married in 1948 and separated in 1952 while living in California. Patricia moved to New York and Cornelius filed for a divorce in Nevada without serving Patricia with process. Patricia did not appear and Nevada issued a final divorce decree.
W then instituted an action in New York for separation and alimony. Although the New York court did not have jurisdiction over H, it sequestered his property within the state to satisfy his obligations to W. H made a special appearance and contended that the New York court was compelled to recognize the Nevada divorce degree under full faith and credit. The New York court found the Nevada decree valid but then entered an order for H to make alimony payments. The Supreme Court granted certiorari.
ISSUE: May a court adjudicate a personal claim or obligation with regard to a party to a lawsuit without personal jurisdiction over that party?
RULE OF LAW: No. A court may not adjudicate a personal claim or obligation with regard to a party to a lawsuit without personal jurisdiction over that party.
HOLDING AND DECISION (Black): The Nevada court had no personal jurisdiction over Patricia and that court was powerless to cut off her support. To the extent that it purported to affect W’s right to support, the Nevada decree was void and New York had no obligation to recognize it under Full Faith and Credit.
DISPOSITION: Affirmed.