In the 1942 case of Williams et al. v. North Carolina, the U.S Supreme Court dealt with issues surrounding divorce and state jurisdiction. The appellants, a married couple originally from North Carolina, moved to Nevada in order to obtain a quicker divorce under Nevada's more lenient laws before marrying each other. Upon returning to their home state of North Carolina, they were charged and convicted for bigamy as North Carolina did not recognize their Nevadan divorces due to lack of domicile in that state at the time of proceedings. The defendants appealed on grounds that this violated Full Faith and Credit Clause which requires states respect public acts, records and judicial proceedings from every other state. The Supreme Court ruled against them by upholding these convictions stating that while states must give "Full Faith and Credit" to court decisions made in other states; it does not require a State blindfold itself towards attempts at fraud upon its policies committed by those who are subjectively bound by them such as domiciliaries seeking divorces elsewhere without bona fide residence requirements being met.

In the dissenting opinion for Williams et al. v. North Carolina, Justice Frank Murphy argued that the majority's decision undermined individual rights and state sovereignty in matters of domestic relations law. He contended that by allowing North Carolina to disregard divorce decrees granted in Nevada on grounds of residency, the Court was effectively permitting states to interfere with each other's jurisdictional authority and ignore their legal obligations under full faith and credit clause of Constitution. Furthermore, he expressed concern about potential harm caused to individuals who had relied on these divorces being legally valid across all states; they could now face criminal charges for bigamy if they remarried within a state like North Carolina which did not recognize their previous divorce decree from another state such as Nevada.