## Facts

- Cornelius Vanderbilt, Jr. and Patricia W. Vanderbilt married in 1948 and separated in 1952 while living in California.
- Patricia moved to New York in February 1953 and resided there thereafter.
- In March 1953, Cornelius filed for divorce in Nevada.
- The Nevada court entered a final divorce decree in June 1953 stating the parties were freed from the marriage and its “duties and obligations.”
- Patricia was not served in Nevada and did not appear; Nevada lacked personal jurisdiction over her.
- In April 1954, Patricia sued in New York for a judgment of separation and for alimony/support.
- New York lacked personal jurisdiction over Cornelius, but sequestered his New York property and appointed a receiver/sequestrator to secure support.
- Cornelius appeared specially and argued the Full Faith and Credit Clause required New York to treat the Nevada decree as terminating any duty of support.
- New York courts treated the Nevada decree as valid to dissolve the marriage but ordered support under New York law; the state’s highest court affirmed.

## Issues

1. Whether an ex parte Nevada divorce decree, entered without personal jurisdiction over the wife, could terminate the wife’s support rights under New York law.
2. Whether the Full Faith and Credit Clause required New York to treat the Nevada decree as extinguishing the husband’s support obligation.

## Decision

- The Supreme Court affirmed the New York judgment (6–2, Justice Black).
- Nevada’s decree was effective to dissolve the marital status.
- Because Nevada lacked personal jurisdiction over the wife, it had no power to adjudicate or extinguish her support rights.
- New York’s support order, secured through sequestration of the husband’s in-state property, did not violate full faith and credit.

## Legal Principles

- A court may dissolve marital status based on one spouse’s domicil, but an ex parte divorce does not necessarily determine economic incidents of the marriage as to an absent spouse (“divisible divorce”).
- A court cannot adjudicate a personal claim or obligation, including the termination of a spouse’s support right, without personal jurisdiction over the affected person.
- Full faith and credit applies only to those aspects of a sister-state judgment rendered within the issuing court’s jurisdiction; a judgment is not entitled to recognition beyond that jurisdictional competence.
- A state may provide support relief by acting against property within its control when personal jurisdiction over the obligor spouse is absent.

## Conclusion

The Court held that Nevada’s ex parte divorce could end the marriage but could not, without personal jurisdiction over the wife, cut off her New York support rights; New York therefore could order support notwithstanding the Nevada decree without violating the Full Faith and Credit Clause.


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