| COLBY v. COLBY | | | | jurisdiction. The court found that the wife was |
| Court of Appeals of Maryland | | | | never a bona fide resident of Nevada and, more |
| May 20, 1958 | | | | importantly, that the husband had never made an |
| Benjamin and Sarah Colby were married in | | | | appearance in the Nevada action. The factual |
| Chicago in 1927, had three children, and lived | | | | point of view, the husband was not in Nevada |
| together in Chevy Chase for over four years | | | | when his wife filed suit and therefore did not have |
| prior to March 4, 1955. On the latter date, the | | | | the "opportunity" referred to by the wife to |
| wife, without prior notice to her husband, took | | | | defend the action on the jurisdictional question. Of |
| their fifteen year old daughter and went to the | | | | course, he could have remained in Nevada to |
| home of the wife's mother in Glencoe, Illinois, and | | | | contest the suit but there is no evidence that he |
| immediately thereafter, went to Las Vegas, | | | | definitely knew when the wife would file suit. |
| Nevada. Exactly six weeks after her arrival, she | | | | Besides he was under no legal compulsion to |
| filed suit for a divorce in Nevada on the ground | | | | remain. Second, it could be argued that the |
| of extreme mental cruelty. She made plans to | | | | husband had the opportunity to employ a Nevada |
| return to Washington after the divorce | | | | attorney to contest the divorce. Such an |
| proceedings by making a reservation at a | | | | opportunity, however, was not sufficient to bar |
| Washington hotel. On June 9, the husband was | | | | the husband from subsequently attacking the |
| served in Washington with Nevada process, and | | | | decree collaterally in this State. The court cited |
| twenty-one days later, the Nevada court granted | | | | several cases in which one party was held to |
| a decree of divorce. | | | | have been barred from contesting an out-of-state |
| The husband made no appearance and the | | | | divorce because that party had either been |
| divorce was granted. The husband later filed an | | | | served in the divorce-granting state or had made |
| action for a divorce a mensa et thoro in Maryland. | | | | an appearance to contest jurisdiction. In this case, |
| The Maryland trial court declared the Nevada | | | | the court found that the husband was not served |
| divorce null and void and granted the husband's | | | | in Nevada and made no appearance there. Thus, |
| petition for a divorce. Appellant wife sought | | | | the husband was entitled to relitigate the issue of |
| review of a decision by the Circuit Court for | | | | jurisdiction. |
| Montgomery County Maryland. | | | | Disclaimer: |
| Whether the husband is estopped from collaterally | | | | These summaries are provided by the SRIS Law |
| attacking the decree of the Nevada court? | | | | Group. They represent the firm's unofficial views |
| The Court rejected the wife's claim that the | | | | of the Justices' opinions. The original opinions |
| husband was barred by the doctrine of res | | | | should be consulted for their authoritative content. |
| judicata from questioning the Nevada court's | | | | |