itution,
they must have been located in the State; as to tangibles and realty
outside the State, the decree of the probate court is entirely at the
mercy of the _lex rei sitae_.[82] So, the probate of a will in one
State, while conclusive therein, does not displace legal provisions
necessary to its validity as a will of real property in other
States.[83]

ADOPTION DECREES

That a statute legitimizing children born out of wedlock does not
entitle them by the aid of the full faith and credit clause to share in
the property located in another State is not surprising, in view of the
general principle--to which, however, there are exceptions (_see_ pp.
675-682)--that statutes do not have extraterritorial operation.[84] For
the same reason adoption proceedings in one State are not denied full
faith and credit by the law of the sister State which excludes children
adopted by proceedings in other States from the right to inherit land
therein.[85]

GARNISHMENT DECREES

A proceeding which combines some of the elements of both an _in rem_ and
an _in personam_ action is the proceeding in garnishment cases. Suppose
that A owes B and B owes C, and that the two former live in a different
State than C. A, while on a brief visit to C's State, is presented with
a writ attaching his debt to B and also a summons to appear in court on
a named day. The result of the proceedings thus instituted is that a
judgment is entered in C's favor against A to the amount of his
indebtedness to B. Subsequently A is sued by B in their home State, and
offers the judgment, which he has in the meantime paid, in defense. It
was argued in behalf of B that A's debt to him had a _situs_ in their
home State, and furthermore that C could not have sued B in this same
State without formally acquiring a domicile there. Both propositions
were, however, rejected by the Court, which held that the judgment in
the garnishment proceedings was entitled to full faith and credit as
against C's action.[86]

FRAUD AS A DEFENSE TO SUITS ON FOREIGN JUDGMENTS

As to whether recognition of a State judgment can be refused by the
forum State on other than jurisdictional grounds, there are _dicta_ to
the effect that judgments, for which extraterritorial operation is
demanded under article IV, section I and acts of Congress, are
"impeachable for manifest fraud." But unless the fraud affected the
jurisdiction of the court, the vast weight of authority is against the
propo