Term: 2005
Docket: 04-1544
Vickie Lynn Marshall v. E. Pierce Marshall
- Pro
04-1544 MARSHALL V. MARSHALL DECISION BELOW: 392 F3d 1118 CERT. GRANTED 9/27/2005 QUESTION PRESENTED: In Markham v. Allen, 326 U.S. 490, 494 (1946), this Court held that Congress did not confer on the federal courts jurisdiction to "probate a will or administer an estate." In the intervening sixty years, some federal circuits have hewn closely to Markham, while others have significantly expanded the scope of the so-called "probate exception," holding that it ousts otherwise proper federal jurisdiction even over claims between parties that are "ancillary" or "related" to probate. Here, the Court of Appeals aligned itself with circuits that have broadly applied the probate exception, holding that although bankruptcy jurisdiction over petitioner's claim was otherwise proper under 28 U.S.C. § 1334, that jurisdiction could not be exercised because petitioner's claim was "probate related." These decisions represent an irreconcilable split among the circuits over the scope of the probate exception. Accordingly, the questions presented are: 1. What is the scope of the probate exception to federal jurisdiction? 2. Did Congress intend the probate exception to apply where a federal court is not asked to probate a will, administer an estate, or otherwise assume control of property in the custody of a state probate court? 3. Did Congress intend the probate exception to apply to cases arising under the Constitution, laws, or treaties of the United States (28 U.S.C. § 1331), including the Bankruptcy Code (28 U.S.C. § 1334), or is it limited to cases in which jurisdiction is based on diversity of citizenship? 4. Did Congress intend the probate exception to apply to cases arising out of trusts, or is it limited to cases involving wills? LOWER COURT CASE NUMBER: 02-56002, 02-56067
The Vickie Lynn Marshall v. E. Pierce Marshall case, also known as the Anna Nicole Smith case, was a complex legal battle involving the estate of J. Howard Marshall II, one of America's wealthiest men. His son, E. Pierce Marshall and his widow (and former Playboy Playmate), Vickie Lynn Marshall were embroiled in a dispute over his vast fortune after he died in 1995 without leaving a clear will or testamentary document behind. In 2005, this dispute reached the U.S Supreme Court which had to decide whether federal courts could hear claims that are also involved in probate proceedings taking place at state level - an area traditionally reserved for state courts only. Vickie claimed that her late husband intended to leave her half of his wealth while Pierce argued she should receive nothing because all gifts during their marriage were made out of love and not obligation. The Supreme Court ruled unanimously that federal bankruptcy court did have jurisdiction to adjudicate Vickie’s counterclaim against Pierce but it didn't make any ruling on who should inherit J.Howard's fortune.
In the dissenting opinion for Vickie Lynn Marshall v. E. Pierce Marshall, Justice Stevens argued that federal courts should not have jurisdiction over state probate matters, as it contradicts the Probate Exception doctrine which prevents federal courts from interfering in such cases. He contended that this case was essentially a dispute over J. Howard's will and thus belonged to Texas state court where it had been originally filed and decided upon favorably for E.Pierce Marshall before being moved to bankruptcy court by Vickie Lynn Marshall (Anna Nicole Smith). The majority decision allowing federal jurisdiction on this matter, according to him, disregarded long-standing principles of comity between state and federal courts while also undermining states' rights in handling their own domestic affairs related to family law or succession issues.
