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In Sawin, Administrator v. Kenny, the Supreme Court of the United States was asked to decide whether a state court had the authority to appoint an administrator to a deceased person's estate when the deceased had not left a will. The Supreme Court held that the state court did have the authority to appoint an administrator in such a situation. The case arose when the deceased, a resident of New York, died without leaving a will. The deceased's brother, Sawin, petitioned the state court to appoint him as administrator of the estate. The state court appointed Sawin as administrator, and he then brought a suit against the deceased's sister, Kenny, to recover certain property that had been left to her by the deceased. Kenny argued that the state court did not have the authority to appoint an administrator in the absence of a will. The Supreme Court disagreed with Kenny and held that the state court did have the authority to appoint an administrator in such a situation. The Court reasoned that the state court had the power to appoint an administrator to protect the interests of the deceased's creditors and heirs. The Court also noted that the appointment of an administrator was necessary to ensure that the deceased's estate was properly administered and that the deceased's debts were paid. In conclusion, the Supreme Court held that the state court had the authority to appoint an administrator to a deceased person's estate when the deceased had not left a will.
In Sawin, Administrator v. Kenny, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by an administrator of a decedent's estate against non-residents who were alleged to have been indebted to the decedent at his death. The majority opinion held that under the Full Faith and Credit Clause of the Constitution, states must give full faith and credit to judgments rendered in other states' courts; however Justice Field dissented from this decision. He argued that while it is true that one state should recognize another's judgment when there is no conflict between their laws or interests involved in such cases, he believed this case did not meet those criteria because there was a difference between New York law (where suit was originally filed) and Massachusetts law (where defendants resided). Furthermore, he argued that since Massachusetts had exclusive jurisdiction over matters concerning its own citizens within its borders then it could not be compelled by any other state or federal authority to enforce foreign judgments on them without their consent. Thus Justice Field concluded that New York lacked jurisdiction in this matter as well as authority for enforcing its judgment against non-resident defendants residing elsewhere.