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Partner A and Partner B were married in State E and lived there for 20 years. Partner A left State E, rented a short-term vacation apartment in State F, and filed for divorce there after satisfying State F's 60-day residency period. Partner A kept a State E medical practice, State E voter registration, and a State E home, but signed a one-year lease extension in State F and testified that the marriage was over and State F felt like a fresh start.
Partner B received notice of the State F divorce action but did not appear. The State F court granted an ex parte divorce on a no-fault ground. Partner A then returned to State E six weeks later to resume the medical practice and sought to remarry. Partner B asks a State E court to refuse recognition of the State F divorce, arguing that Partner A never became domiciled in State F. Partner A argues that State E must recognize the decree because State F found jurisdiction.
Discuss whether State E must recognize the State F divorce decree and how the answer would differ if Partner B had appeared in State F and litigated domicile before the decree was entered.