Marshall v. Marshall (2006) 547 U.S. 293

The Supreme Court reversed a judgment against GMSR’s client, Anna Nicole Smith, rejecting arguments that claims based on interference with inter vivos trust were subject to the so-called “probate exception” to federal jurisdiction.

“Among longstanding limitations on federal jurisdiction otherwise properly exercised are the so-called ‘domestic relations’ and ‘probate’ exceptions.  Neither is compelled by the text of the Constitution or federal statute….   Nevertheless, the Ninth Circuit in the instant case read the probate exception broadly to exclude from the federal courts’ adjudicatory authority ‘not only direct challenges to a will or trust, but also questions which would ordinarily be decided by a probate court in determining the validity of the decedent’s estate planning instrument.’  [Citation.]  The Court of Appeals further held that a State’s vesting of exclusive jurisdiction over probate matters in a special court strips federal courts of jurisdiction to entertain any ‘probate related matter,’ including claims respecting ‘tax liability, debt, gift, [or] tort.’  [Citation.]  We hold that the Ninth Circuit had no warrant from Congress, or from decisions of this Court, for its sweeping extension of the probate exception.”

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