RESPONDENT: E. Pierce Marshall
LOCATION: Board of Immigration Appeals
DOCKET NO.: 04-1544
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Ninth Circuit
CITATION: 547 US 293 (2006)
GRANTED: Sep 27, 2005
ARGUED: Feb 28, 2006
DECIDED: May 01, 2006
Deanne E. Maynard - argued the cause for Petitioner
G. Eric Brunstad, Jr. - argued the cause for Respondent
Kent L. Richland - argued the cause for Petitioner
Facts of the case
Vickie Lynn Marshall (a.k.a. Anna Nicole Smith) was involved in a dispute in Texas Probate Court over the estate of her late husband, J. Howard Marshall. While the state-court proceedings were ongoing, Ms. Marshall filed for bankruptcy in federal court. E. Pierce Marshall, J. Howard's son, filed a claim alleging that Ms. Marshall had defamed him, and she filed a counterclaim alleging that E. Pierce had interfered with a gift she expected from her late husband's estate. The bankruptcy court ruled for Ms. Marshall and awarded her a large monetary award. Later, the probate court found J. Howard's will valid and ruled for his son. Under the judicially-created "probate exception" to federal jurisdiction, federal courts do not interfere with state-court judgments concerning wills and estates. E. Pierce Marshall appealed the bankruptcy court decision (awarding Ms. Marshall a large monetary award) to federal district court, invoking the probate exception to argue that the court had no jurisdiction. The district court disagreed and ruled for Ms. Marshall, holding that since her claim did not require invalidating the will, the probate exception did not apply. The Ninth Circuit reversed, broadly interpreting the probate exception as covering any question that would normally be handled in probate court.
(1) What is the scope of the "probate exception" to federal jurisdiction? (2) Does the exception apply to cases that do not directly involve the administration of a will or estate?
Media for Marshall v. MarshallAudio Transcription for Oral Argument - February 28, 2006 in Marshall v. Marshall
Audio Transcription for Opinion Announcement - May 01, 2006 in Marshall v. Marshall
John G. Roberts, Jr.:
Justice Ginsburg has the opinion in 04-1544, Marshall versus Marshall.
Ruth Bader Ginsburg:
This case concerns the claim of petitioner Vickie Lynn Marshall to share in the large fortune of her deceased husband, J. Howard Marshall.
Petitioner alleges that J. Howard intended to provide for her well-being after his death by placing in trust for her benefit one-half of the appreciation of his assets from the date of their marriage in June 1994 until the date of his death in August 1995.
Vickie centrally asserts that J. Howard’s son, E. Pierce Marshall, respondent in this case and ultimate beneficiary of J. Howard’s estate plan, tortiously impeded her receipt of the precisely described gift she anticipated.
The contest between Vickie and Pierce played out on two fronts, in a Texas probate court and in federal bankruptcy and district courts.
Pierce was the victor in the state probate court; Vickie prevailed in the federal trial-court proceedings.
Asserting that the only the Texas probate court had authority to deal with the dispute, Pierce invoked the so-called probate exception to the exercise of federal-court jurisdiction.
The U.S. District Court rejected that plea, but the U.S. Court of Appeals for the 9th Circuit agreed with Pierce that the probate exception applied, rendering the Texas probate court exclusively competent to resolve the dispute.
We reverse that determination.
Our opinion discusses two limitations on the exercise of federal jurisdiction, the so-called domestic relations and probate exceptions.
Neither is compelled by the text of the Constitution or Federal Statute.
Both are judicially created doctrines stemming, in large measure, from misty understandings of English legal history.
In a 1992 decision, Ankenbrandt v. Richards, this Court reigned in the domestic-relations exception, confining it to divorce, alimony and child-custody decrees and rejecting more expansive interpretations.
Earlier, in a 1946 decision, Malcolm against Allen, the Court endeavored similarly to contain the probate exception.
That decision upheld federal-court jurisdiction in the case than before the courts.
But Malcolm caused confusion because of its less than meticulously crafted language.
Malcolm stated that federal jurisdiction, otherwise proper, could be exercised in matters relating to a decedent’s fortune, so long as the federal court does not interfere with the probate proceedings.
Some lower federal courts, including the Court of Appeals for the 9th Circuit, read the words “interfere with” expansively to block federal jurisdiction over a range of matters well beyond the admission of a will to probate or the administration of a decedent’s estate.
We hold today that the probate exception reserves to state courts the probate or annulment of a will and the administration of a decedent’s estate.
It also, and most importantly, precludes federal courts from disposing of property that is in the custody of a state court.
But that is the sum and substance of it.
The probate exception does not bar federal courts from adjudicating matters outside those confines and otherwise within federal jurisdiction.
Vickie Marshall’s claim, we explain, falls entirely outside the tight bounds of the probate exception and, as the District Court held, qualifies for adjudication in federal court.
While we reverse the 9th Circuit’s judgment, we note issues remaining open for that court’s consideration on remand.
Justice Stevens has filed an opinion concurring in part and concurring in the judgment.