In the case of Sistare v. Sistare, 1909, the U.S Supreme Court was tasked with determining whether a wife residing in Connecticut could legally claim alimony from her husband who lived in New York and had obtained a divorce decree there. The court ruled that under full faith and credit clause of the Constitution, Connecticut courts were obligated to recognize New York's jurisdiction over its own residents regarding matters of marital status and therefore must respect its divorce decrees. However, it also held that this obligation did not extend to financial provisions such as alimony which are separate from questions of marital status itself. Therefore, while Connecticut must acknowledge the validity of the New York divorce decree dissolving their marriage bond, it was not required to accept or enforce any accompanying order denying Mrs. Sistare an award for maintenance (alimony). This decision established important precedent concerning interstate recognition and enforcement of family law orders.

In the dissenting opinion for Sistare v. Sistare, Justice Harlan argued that the majority's decision was a departure from established principles of law and equity. He contended that it was not within the jurisdiction of Connecticut courts to modify or alter a decree made by New York courts concerning alimony payments, as such an action would infringe upon New York's sovereignty. Furthermore, he believed that Mrs. Sistare should have been allowed to pursue her claim in Connecticut where Mr. Sistare resided and had property since she could not enforce her rights in New York due to his absence there. In essence, Justice Harlan disagreed with the majority’s view on full faith and credit clause application between states regarding divorce decrees; he maintained this case involved enforcement rather than recognition of another state’s judgment.