Keating v. Keating

Summary

The Pennsylvania Superior Court held that a Guam divorce decree was not entitled to recognition because the wife received neither notice nor an opportunity to be heard in the Guam proceedings. The court further held that the wife was not estopped from challenging the decree and affirmed the declaratory judgment recognizing her as the decedent’s legal widow.

Holdings

1. Pennsylvania need not give full faith and credit to the Guam divorce decree because Jean was not afforded notice or a fair opportunity to be heard; the decree was therefore a nullity, and Jean remained Benjamin's legal wife at the time of his death.
2. Jean was not equitably estopped from collaterally attacking the Guam divorce decree because the evidence did not establish that she accepted spousal support or the marital-home interest in reliance on or acquiescence to the decree.

Questions Presented

1. Whether Pennsylvania was required to give full faith and credit to the Guam divorce decree when Jean received no notice or opportunity to be heard in the Guam proceeding.
2. Whether Jean was equitably estopped from collaterally attacking the Guam divorce decree based on her receipt of spousal support and Benjamin's interest in the marital home.

Disposition

affirmed