In Whitney v. Morrow, the Supreme Court of the United States was asked to decide whether a state court had the authority to grant a divorce to a couple who had been married in another state. The couple had been married in New York, but the wife had since moved to California. The husband had filed for divorce in California, but the state court had denied his request. The husband then appealed to the Supreme Court, arguing that the state court had no authority to deny his request for a divorce. The Supreme Court held that the state court did have the authority to grant a divorce, as long as the divorce was granted in accordance with the laws of the state in which the couple had been married. The Court noted that the state court had the power to grant a divorce, but only if the divorce was granted in accordance with the laws of the state in which the couple had been married. The Court also noted that the state court had the power to grant a divorce, even if the couple had moved to another state. In conclusion, the Supreme Court held that the state court had the authority to grant a divorce to the couple, as long as the divorce was granted in accordance with the laws of the state in which the couple had been married. The Court also noted that the state court had the power to grant a divorce, even if the couple had moved to another state.

In Whitney v. Morrow, the Supreme Court was asked to decide whether a state court had jurisdiction over an action brought by two citizens of California against a citizen of Oregon in order to recover damages for injuries sustained on board an Oregon vessel while it was navigating the waters of that state. The majority opinion held that under the Constitution and laws of the United States, such suits could not be maintained in any other than a federal court. Justice Field dissented from this decision, arguing that since Congress had not provided for exclusive jurisdiction in cases involving vessels navigating between different states or territories, then each state should have concurrent jurisdiction with its own courts over such matters as long as they did not conflict with existing federal law. He further argued that allowing individuals to bring suit before their home-state courts would provide them with more efficient access to justice than having them travel across multiple states just to file suit in a distant federal court.