Sherrer v. Sherrer 334 U.S. 343, 68 S.Ct. 1087, 92 L.Ed. 1429 (1948) Margaret and Edward were married in Massachusetts and lived together for 14 years until Margaret took the kids and moved to Florida, claiming she needed a vacation. Margaret lived in Florida for 3 months and then filed for divorce. Margaret claimed she was a 'bona fide resident of Florida', and so Florida had jurisdiction to grant the divorce. Edward got a Florida attorney and contested the divorce. But failed to challenge Florida's jurisdiction. That's a general appearance. Edward also drove down and made a personal appearance. The Florida Trial Court found that they had jurisdiction and granted the divorce. Edward did not appeal. The Florida Trial Court accepted Margaret's contention that she was domiciled in Florida. A few months later, Margaret married in Henry in Florida and moved back to Massachusetts. Under the ruling in Williams v. North Carolina (317 U.S. 287 (1942)), Massachusetts has to give full faith and credit to Florida divorce decrees. Edward sued in Massachusetts, claiming that the Florida divorce was not valid and therefore Margaret's marriage to Henry was void. Under the ruling in Williams v. North Carolina (325 U.S. 226 (1945)), a State can challenge whether or not another State had jurisdiction. The Massachusetts Trial Court found that Margaret was never domiciled in Florida, and therefore Florida's divorce decree was not valid. Margaret appealed. At the time, in order to obtain a divorce in a State you had to be legally domiciled in that State. In general that means that you have to live there for a specific period of time and have the intent to remain there. Margaret probably never intended to stay in Florida, she was just looking for a State with quicky divorce laws. The Massachusetts Supreme Court affirmed. Margaret appealed. The Massachusetts Supreme Court found that the requirements of full faith and credit did not preclude Massachusetts from reexamining the finding of domicile by the Florida Court. The US Supreme Court reversed. The US Supreme Court found that Edward appeared in the Florida Court and failed to raise the issue. Therefore he missed his chance (aka res judicata). The Court found that there needs to be a finality to a divorce decree, and it isn't good public policy to permit a situation where one State (Florida) finds a couple divorced, and another State (Massachusetts) finds them still married. Therefore there is an obligation for States to apply full faith and credit to divorce decrees. Otherwise, there could be sticky situations. If Margaret and Henry lived in Massachusetts, they would not be married, but if they stayed in Florida they would be. That adds a lot of confusion. What if Margaret dies? Who would inherit? Basically, if you make a general appearance, or hire an attorney to make an appearance in a State to contest the divorce, that State automatically gets jurisdiction to grant a divorce. You can no longer go to another State and claim that the granting State did not have jurisdiction to grant the divorce. Edward should have made a special appearance, which would not have been a submission to Florida jurisdiction.