Vanderbilt v. Vanderbilt,
354 U.S. 416 (1957).


Procedure:Respondent wife filed an action for separation and alimony. Petitioner husband sought to have his Nevada divorce recognized under the Full Faith and Credit Clause of the U.S. Constitution. The Court of Appeals of New York recognized the Nevada divorce and affirmed the support order issued by the lower court. Petitioner applied for certiorari.

Facts: Patricia (P) and Cornelius (D) Vanderbilt were married in 1948 and separated in 1952 while living in California. P moved to New York. Later that year, D sought a divorce from P in Nevada, which was granted and provided that both P and D were "freed and released from the bonds of matrimony and all the duties and obligations thereof." P was not served with process in Nevada and did not appear before the divorce court. Afterward, P sought and was granted support payments for separation in spite of D's claim that the Full Faith and Credit Clause required the New York courts to accept the Nevada Decree. The New York Court of Appeals affirmed. D appeals.


Issue: May a court adjudicate a personal claim or obligation without personal jurisdiction over a party to the lawsuit1?


Holding: No. Judgment affirmed.
The Supreme Court, Mr. Justice Black, held that where husband secured a valid divorce in Nevada from New York domiciled wife in an action in which wife was not served with process in Nevada and did not appear before the divorce court, Nevada divorce court had no power to extinguish any right which wife had under law of New York, to financial support from husband.

Analysis:The husband argued that his Nevada divorce decree, which terminated the marriage and destroyed any duty he owed his wife, was entitled to recognition under the Full Faith and Credit Clause. The husband argued that the alimony order violated the terms of his divorce decree. The Court held that that the Nevada divorce court had no power to extinguish any right which the wife might have under the law of New York to financial support from her husband because the wife was not served with process and was not subject to the personal jurisdiction of the Nevada divorce court. The Court reasoned that the divorce court could not adjudicate a personal claim or obligation unless it had jurisdiction over the person of the wife.