ce;
and when the Florida court ruled that she was a _bona fide_ resident,
the husband did not appeal. Inasmuch as the findings of the requisite
jurisdictional facts, unlike those in the Second Williams Case, were
made in proceedings in which the defendant appeared and participated,
the requirements of full faith and credit were held to bar him from
collaterally attacking such findings in a suit instituted by him in his
home State of Massachusetts, particularly in the absence of proof that
the divorce decree was subject to such collateral attack in a Florida
court. Having failed to take advantage of the opportunities afforded him
by his appearance in the Florida proceeding, the husband was thereafter
precluded from re-litigating in another State the issue of his wife's
domicile already passed upon by the Florida court.
In Coe _v._ Coe,[68] embracing a similar set of facts, the Court applied
like reasoning to reach a similar result. Massachusetts again was
compelled to recognize the validity of a six-week Nevada decree obtained
by a husband who had left Massachusetts after a court of that State had
refused him a divorce and had granted his wife separate support. In the
Nevada proceeding, the wife appeared personally and by counsel filed a
cross-complaint for divorce, admitted the husband's residence, and
participated personally in the proceedings. After finding that it had
jurisdiction of the plaintiff, defendant, and the subject matter
involved, the Nevada court granted the wife a divorce, which was valid,
final, and not subject to collateral attack under Nevada law. The
husband married again, and on his return to Massachusetts, his ex-wife
petitioned the Massachusetts court to adjudge him in contempt for
failing to make payments for her separate support under the earlier
Massachusetts decree. Inasmuch as there was no intimation that under
Massachusetts law a decree of separate support would survive a divorce,
recognition of the Nevada decree as valid accordingly necessitated a
rejection of the ex-wife's contention.
Appearing to revive Williams II, and significant for the social
consequences produced by the result decreed therein, is the recent case
of Rice _v._ Rice.[69] To determine the widowhood status of the party
litigants in relation to inheritance of property of a husband who had
deserted his first wife in Connecticut, had obtained an _ex parte_
divorce in Nevada, and after remarriage, had died without ever ret
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