In the 1947 U.S. Supreme Court case Coe v. Coe, the court was tasked with determining whether or not a Nevada divorce decree could be recognized in Virginia, where one of the parties involved had been domiciled at the time of divorce proceedings. The couple married in Virginia and later moved to Nevada for six weeks - a period sufficient under Nevada law to establish residency and obtain a divorce but insufficient by Virginia standards. After obtaining their divorce in Nevada, Mrs. Coe returned to Virginia while Mr. Coe remained in California; both remarried other people subsequently. The issue arose when Mrs.Coe died and her new husband claimed rights as surviving spouse against Mr.Coe's claim that he was still legally married to his former wife since their original marriage hadn't been dissolved validly according to Virginian laws. The Supreme Court ruled that full faith and credit should be given by all states towards public acts, records, judicial proceedings etc., from any state within United States (as per Article IV Section 1 of US Constitution). Therefore it upheld validity of Nevadan Divorce Decree even though domicile requirements differed between two states.

In the dissenting opinion for Coe v. Coe, 1947, it was argued that the court should not have jurisdiction over a divorce granted in Nevada to a couple who were residents of California at the time of their marriage and had only temporarily relocated to Nevada for the purpose of obtaining a divorce. The dissenting justices believed that this decision undermined states' rights by allowing individuals to circumvent their home state's laws simply by moving temporarily. They also expressed concern about potential abuse of such lenient residency requirements and suggested that this could lead to "divorce tourism," where people travel specifically with an intent to exploit more favorable divorce laws elsewhere. Furthermore, they disagreed with majority’s interpretation regarding domicile requirement as it contradicted previous rulings which required genuine change in residence rather than mere physical presence.