Bleich v. Bleich
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The Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's complaint seeking dissolution of her marriage to Defendant, holding that the district court erred by dismissing this action for lack of subject matter jurisdiction.
In his motion to dismiss, Defendant asserted that the parties were legally divorced in Venezuela, and therefore, the district court lacked subject matter jurisdiction over the dissolution action under Rule 12(b)(1) and lacked personal jurisdiction over Defendant under Rule 12(b)(2). The district court sustained the motion to dismiss. The Supreme Court reversed, holding (1) the district court erred in concluding that it lacked subject matter jurisdiction over the dissolution action because the complaint's allegations sufficiently established the court's subject matter jurisdiction over the marital relationship; and (2) the district court erred to the extent it relied on its equitable estoppel findings to support dismissal for lack of subject matter jurisdiction.
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