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Johnson v. Muelberger

340 U.S. 581, 71 S. Ct. 474, 95 L. Ed. 552 (1951)

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Johnson v. Muelberger

United States Supreme Court

340 U.S. 581, 71 S. Ct. 474, 95 L. Ed. 552 (1951)

Facts

Eleanor Johnson Muelberger was the daughter of E. Bruce Johnson’s first marriage and his legatee. E. Bruce Johnson was on his third marriage when he died. E. Bruce Johnson’s second marriage ended in a valid and final divorce decree entered by a Florida court—although the couple’s marital home was in New York. E. Bruce Johnson’s will bequeathed his entire estate to Eleanor, but after his death and during the New York probate of his will, his third wife elected to take her one-third share of the estate under New York law. Eleanor contested the third wife’s surviving-spouse status by arguing that the Florida divorce decree was invalid due to a lack of proper jurisdiction. The New York trial court found that because the parties to the second divorce had a full and fair opportunity to contest the court’s jurisdiction in that proceeding, the resulting valid and final judgment was not subject to collateral attack in the New York probate proceeding. The appellate court affirmed, but the New York Court of Appeals reversed because it found that the Florida judgment bound only the parties to that action, which included only Eleanor’s father and his second wife, but not Eleanor. The third wife appealed.

Rule of Law

Issue

Holding and Reasoning (Reed, J.)

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