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Fall v. Eastin

United States Supreme Court
215 U.S. 1 (1909)


Facts

E.W. Fall and his wife W.H. (plaintiff) acquired land in Nebraska while residing there. The Falls later moved to Washington but retained the Nebraska land. In 1895, Mr. Fall instituted a divorce action against Mrs. Fall in a Washington court. He alleged that he was the sole owner of the Nebraska land. Mrs. Fall filed a cross-complaint. The Washington court granted a divorce and awarded Mrs. Fall the Nebraska land as separate property. The court ordered Mr. Fall to execute a deed to her. When Mr. Fall refused to do so, a court-appointed commissioner executed a deed to Mrs. Fall. Mr. Fall executed a deed to the same land to Elizabeth Eastin (defendant). In 1897, Mrs. Fall filed suit in a Nebraska court to quiet title to the land and to cancel the deed purporting to transfer the land from Mr. Fall to Eastin. The trial court entered a decree in Mrs. Fall’s favor; its decision was affirmed by the Nebraska Supreme Court. On rehearing, the judgment was reversed. Mrs. Fall petitioned the United States Supreme Court for certiorari, arguing that full faith and credit required Nebraska to enforce the deed to her.

Rule of Law

Issue

Holding and Reasoning (McKenna, J.)

Concurrence (Holmes, J.)

Dissent (Harlan, J.)

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