Vanderbilt v. Vanderbilt

Cornelius Vanderbilt IV went to Reno, Nevada, to get an ex parte divorce in the 1950s. He was seeking to divorce his 4th of what 7 marriages he would have. His 4th wife, in turn, sued Vanderbilt IV for alimony in the state of New York.

In 1948, Vanderbilt IV married Patricia Murphy. In 1952, while both were living in California, they decided to separate. Patricia moved to New York in February 1953.

In March 1953, Cornelius Vanderbilt IV filed for divorce in Nevada. Patricia wasn't served divorce papers from the Nevada court. She didn't appear in the Nevada court either.

In 1954, Patricia Murphy filed for legal separation in New York & sued for alimony.

Cornelius IV appeared in the New York court. The New York court recognized his Nevada divorce, but with the added twist that Cornelius IV had to make alimony payments to Patricia.

Is a financial settlement accompanying an ex parte divorce decree [here, in Nevada] enforceable against a defendant [Patricia in New York] over whom the court lacks personal jurisdiction?

No. Although an ex parte divorce's marriage dissolution is entitled to full faith & credit, a financial settlement in Nevada entered without personal jurisdiction over the defendant in New York is not.

Cornelius Vanderbilt IV owned property in the state of New York in the 1950s. Thus, the New York court claimed personal jurisdiction over Cornelius Vanderbilt IV in addition to his former 4th wife living in New York.