Full Faith and Credit—Fraud in Procurement of Personal Service—Divorce—Domicile

If some future savant should perchance decipher the remains of any law review, he is almost certain to discover an article on full faith and credit, migratory divorce, and sundry allied problems of jurisdiction, domicile, service of process, and res judicata. This inquiry is but another attempt to state what part of the law in this area may be at the present time with particular reference to a recent Nebraska case, zenker v. zenker, which raises some interesting questions regarding the never, never land of full faith and credit. If married persons always had a common domicile there would be far less difficulty in determining which court has the power to grant a divorce entitled to recognition in sister states. But since husbands and wives in the United States may secure separate domiciles quite freely, the jurisdictional problem becomes one of great complexity