In 1995, Wife (plaintiff), a non-Indian resident of Rhode Island, filed a divorce action in Connecticut state court. Husband (defendant) was a member of the Mashantucket Pequot Indian Tribe, located in Connecticut. Husband and Wife had been married in Connecticut outside Mashantucket land. The Connecticut court granted the divorce decree, and Wife sought to enforce the judgment in the Mashantucket Pequot Family Court. Husband disputed the action to enforce judgment. Husband claimed that the Connecticut divorce decree was invalid, because neither Husband, a resident of the Mashantucket reservation, nor Wife, a resident of Rhode Island, satisfied Connecticut’s 12-month residency requirement for bringing an action in divorce. The family court enforced the divorce decree. Husband appealed.