ferent from that required to alter the marital status
with extraterritorial effect."[63]

Three years later, but on this occasion as spokesman for a majority of
the Court, Justice Douglas reiterated these views in the case of Estin
_v._ Estin.[64] Even though it acknowledged the validity of an _ex
parte_ Nevada decree obtained by a husband, New York was held not to
have denied full faith and credit to said decree when, subsequently
thereto, it granted the wife a judgment for arrears in alimony founded
upon a decree of separation previously awarded to her when both she and
her husband were domiciled in New York. The Nevada decree, issued to the
husband after he had resided there a year and upon constructive notice
to the wife in New York who entered no appearance, was held to be
effective only to change the marital status of both parties in all
States of the Union but ineffective on the issue of alimony. Divorce, in
other words, was viewed as being divisible; and Nevada, in the absence
of acquiring jurisdiction over the wife, was held incapable of
adjudicating the rights of the wife in the prior New York judgment
awarding her alimony. Accordingly, the Nevada decree could not prevent
New York from applying its own rule of law which, unlike that of
Pennsylvania,[65] does permit a support order to survive a divorce
decree.[66] Such a result was justified as accommodating the interests
of both New York and Nevada in the broken marriage by restricting each
State to matters of her dominant concern, the concern of New York being
that of protecting the abandoned wife against impoverishment.

RECENT CASES

Fears registered by the dissenters in the second Williams Case that the
stability of all divorces might be undermined thereby and that
thereafter the court of each forum State, by its own independent
determination of domicile, might refuse recognition of foreign decrees
were temporarily set at rest by the holding in Sherrer _v._ Sherrer,[67]
wherein Massachusetts, a state of domiciliary origin, was required to
accord full faith and credit to a 90-day Florida decree which had been
contested by the husband. The latter, upon receiving notice by mail,
retained Florida counsel who entered a general appearance and denied all
allegations in the complaint, including the wife's residence. At the
hearing the husband, though present in person and by counsel, did not
offer evidence in rebuttal of the wife's proof of her Florida residen