Rice v. Rice

Background

A Connecticut woman challenged a Nevada divorce that her husband obtained and then used to marry another woman. She sued in Connecticut to be declared his widow for purposes of Connecticut property law after he died intestate. The Connecticut trial court and the state supreme court found that the husband had not established a bona fide domicile in Nevada. The new wife and the administrator of the estate were defendants in the Connecticut action.

Reasoning

The central question was whether Connecticut gave the Nevada divorce the full faith and credit the Constitution requires. The Supreme Court reviewed the record and the Connecticut courts’ procedures and evidence. The Court concluded Connecticut had properly weighed Nevada’s claims of power, placed the burden on the challenger to prove lack of domicile, and fairly tried the factual issue. The national Court therefore affirmed the Connecticut rulings that the Nevada decree did not receive full faith and credit in this case.

Real world impact

The ruling means a state can reexamine whether someone really became a resident elsewhere before accepting that state’s divorce for purposes like inheritance and marital status. People who rely on quick out-of-state divorces may find their later legal status — for example, who is a widow or who inherits real property — can be decided differently by other states. This decision affirmed that factual findings about domicile, when fairly tried and supported by evidence, can defeat recognition of an out-of-state divorce.

Dissents or concurrances

Justice Jackson dissented, arguing that the case mainly reexamined evidence and that the Nevada finding of domicile should have been given full credit; he warned the Court’s approach compounds confusion in interstate divorce law.