Marshall v. Marshall

164 L. Ed. 2d 480 · Supreme Court of the United States · 2006

Facts

Vickie Lynn Marshall (Anna Nicole Smith), widow of J. Howard Marshall II, filed for bankruptcy. J. Howard's son, E. Pierce Marshall, filed a defamation claim against Vickie, who counterclaimed for tortious interference with an expected gift/inheritance, alleging Pierce prevented J. Howard from providing for her. The Bankruptcy Court ruled for Vickie, but the Ninth Circuit reversed, broadly interpreting the 'probate exception' to federal jurisdiction.

Issue

Does the federal 'probate exception' to jurisdiction bar a federal court from adjudicating a tortious interference claim against a beneficiary of an estate, where the claim does not involve probating a will, administering an estate, or disposing of property in state court custody? Can a state's exclusive jurisdiction over probate matters strip federal courts of jurisdiction over related claims?

Holding

The Supreme Court reversed the Ninth Circuit, holding that the probate exception does not bar federal jurisdiction over Vickie's tortious interference claim. The Ninth Circuit's broad interpretation of the exception was unwarranted, and a state cannot reserve exclusive jurisdiction over a transitory tort to its probate courts to defeat federal jurisdiction.

Rule

The probate exception to federal jurisdiction is narrow, reserving to state probate courts only the probate or annulment of a will and the administration of a decedent’s estate, and precluding federal courts from disposing of property in state probate court custody. It does not bar federal courts from adjudicating in personam tort claims, even if related to an estate, nor can state law dictate federal subject-matter jurisdiction over such claims.

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Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.