334 U.S. 541 (1948), U.S. Supreme Court
Estin v. Estin is a cornerstone of American conflict-of-laws and family law, crystallizing the "divisible divorce" doctrine and clarifying how the Full Faith and Credit Clause applies to ex parte divorces.
Does the Full Faith and Credit Clause require New York to recognize a Nevada ex parte divorce decree so broadly that it extinguishes the wife's right to alimony under a prior New York separation judgment, even though Nevada lacked personal jurisdiction over the wife?
A state must give full faith and credit to a sister state's divorce decree as to dissolution of marital status if the decreeing state had jurisdiction based on domicile. However, an ex parte divorce decree obtained without personal jurisdiction over the nonappearing spouse cannot adjudicate or terminate that spouse's personal rights—such as alimony or other in personam obligations—previously established by another state's valid judgment. Status and support are therefore divisible for full faith and credit purposes.
New York must recognize the Nevada decree as validly dissolving the marriage, but it need not give effect to the decree to extinguish the wife's right to alimony under the prior New York separation judgment. The ex parte Nevada divorce did not and could not terminate that in personam obligation absent personal jurisdiction over the wife. The New York courts' enforcement of the alimony judgment was affirmed.
Estin anchors the divisible divorce doctrine: an ex parte divorce may change marital status but does not automatically affect support or property rights without personal jurisdiction. It refines Full Faith and Credit analysis by tying the scope of interstate preclusion to the rendering court's jurisdictional competence. For students, Estin teaches careful parsing of the relief granted—status versus in personam obligations—and the centrality of jurisdiction in determining whether a sister-state decree must be honored. The decision also foreshadows later cases, such as Vanderbilt v. Vanderbilt, which extended the principle to support rights not reduced to judgment before the ex parte divorce.