Marshall v. Marshall
164 L. Ed. 2d 480 · Supreme Court of the United States · 2006
Facts
Vickie Lynn Marshall (Anna Nicole Smith), widow of J. Howard Marshall II, filed for bankruptcy. J. Howard's son, E. Pierce Marshall, filed a defamation claim against Vickie, who counterclaimed for tortious interference with an expected inheritance, alleging Pierce prevented J. Howard from providing for her. The Ninth Circuit broadly applied the probate exception to bar federal jurisdiction over Vickie's claim.
Procedural history
Vickie filed for Chapter 11 bankruptcy in the U.S. Bankruptcy Court for the Central District of California. Pierce filed a claim, and Vickie counterclaimed for tortious interference, winning a judgment of over $449 million compensatory and $25 million punitive damages. The District Court, reviewing de novo, affirmed the tortious interference finding and awarded $44.3 million compensatory and equal punitive damages. The Court of Appeals for the Ninth Circuit reversed, broadly interpreting the probate exception to bar federal jurisdiction. The Supreme Court granted certiorari to resolve confusion regarding the probate exception's scope.
Issue
Does the federal probate exception to jurisdiction bar a tortious interference claim related to an inheritance, particularly when a state court claims exclusive jurisdiction over probate matters?
Holding
No, the Supreme Court reversed the Ninth Circuit, holding that the probate exception is narrow and does not bar federal jurisdiction over Vickie's tortious interference claim, which seeks an in personam judgment and does not interfere with property in state court custody.
Rule
The probate exception is limited to the probate or annulment of a will, the administration of a decedent's estate, and precluding federal courts from disposing of property in state probate court custody. It does not bar federal courts from adjudicating matters outside these confines, nor can a state's claim of exclusive jurisdiction over a transitory tort defeat federal jurisdiction.
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