Fall v. Eastin

E.W. and W.H. Fall (plaintiff) acquired land in Nebraska while living there, then moved to Washington but kept the land. Mr. Fall later sued for divorce in Washington, and the court awarded the Nebraska land to Mrs. Fall as separate property, ordering Mr. Fall to execute a deed to her. When he refused, a court-appointed commissioner executed the deed for him — but Mr. Fall then separately deeded the same land to Elizabeth Eastin (defendant). Mrs. Fall sued in Nebraska to quiet title against Eastin's deed and enforce her own, invoking full faith and credit for the Washington decree.