Riley v. N.Y. Tr. Co. - 315 U.S. 343, 62 S. Ct. 608 (1942)

Rule:

Article IV, § 1, of the Constitution compels that controversies be stilled, so that, where a state court has jurisdiction of the parties and subject matter, its judgment controls in other states to the same extent as it does in the state where rendered. This is true even though the cause of action merged in the judgment could not have been enforced in the state wherein the enforcement of the judgment is sought.

Facts:

Coca-Cola International Corporation, incorporated in Delaware, filed an interpleader action in a Delaware Court of Chancery against the petitioners Julian Riley and Hughes Spalding, the Executors of Julia M. Hungerford, with letters testamentary issued by the Court of Ordinary of Fulton County, Georgia, and against the respondent, The New York Trust Company, a New York corporation, as temporary administrator (afterward administrator c. t. a.) of the same decedent, appointed by the Surrogate's Court for New York County, New York. Petitioner and respondent each claimed the right to have transferred to them, in their representative capacity, stock of the Coca-Cola International Corporation in the name of the decedent. Petitioners asserted that original domiciliary probate of the decedent’s will in solemn form was obtained by them in Georgia, with all beneficiaries and heirs at law of testatrix, including her husband, Robert Hungerford, actual parties by personal service. On the other hand, respondent denied that the decedent was domiciled in Georgia or that the Georgia judgment of domicile and probate was binding on it, and averred that the decedent’s domicile at death was New York. It further averred that there were New York creditors of the estate interested in the proper and lawful administration of the estate, and that New York had certain claims for inheritance and estate taxes. The trial court concluded from the evidence adduced at the hearings that the decedent was domiciled in Georgia. The Supreme Court of Delaware reversed this finding of fact, determined that New York was the decedent’s domicile and denied petitioners' contention that Article IV, § 1, of the Constitution required the award of the certificates of stock to the Georgia executors. The Coca-Cola Corporation was directed to issue its stock certificate to the respondent, the New York administrator. Petitioners sought review of the state supreme court’s decision. Certiorari was granted.

Issue:

Did the Georgia judgment on domicile conclusively establish the right of the Georgia executors to demand delivery to them of personal assets of the decedent?

Answer:

No.

Conclusion:

On appeal, the Court affirmed the judgment of the state supreme court. The Court held that the Georgia judgment of probate was in rem and that so far as it affected personalty beyond the state, it was in personam and could bind only parties thereto or their privies. The Court stated that the effect of the probate decree in Georgia in personam was not to bar a stranger, the administrator in this case, to the decree from later asserting his rights.