Eric Manuelian v. Jennifer Starr, Individually and in Her Official Capacity as Trustee of the Laura Kirkland Trust dated 3/10/05 and in the Capacity as Trustee of the Starr Trust, et al.

The Full Faith and Credit Clause, Article IV, Section 1 of the United States Constitution, provides that full faith and credit “shall be given in each State to . . . judicial Proceedings of every other State.” In 1997, a South Carolina Court entered a final judgment of divorce providing that shares of a Florida corporation then owned by Laura Kirkland were to be divided upon her death between her surviving children. Eric Manuelian, Petitioner, is a surviving natural son. Before Laura Kirkland’s death in 2009, Laura Kirkland transferred the shares to herself, Laura Kirkland, as trustee of her own Florida grantor revocable trust and named Respondent Jennifer Starr as sole beneficiary and successor trustee upon the death of Laura Kirkland. After the transfer of the shares to herself as trustee, Laura Kirkland died. Jennifer Starr claims the shares as beneficiary and successor trustee of Laura Kirkland’s Florida trust. Eric Manuelian claims the shares under the terms of the South Carolina divorce judgment. The Florida courts held that the transfer by Laura Kirkland to herself, Laura Kirkland, as trustee, extinguished any interest of Eric Manuelian created by the South Carolina divorce judgment and awarded the shares to Jennifer Starr. The questions presented are:

1. Does the Florida judgment violate the Full Faith and Credit Clause?

2. To the extent that this Petition is deemed to seek error-correction, does this case warrant summary reversal?