Ellingburg v. United States · ¶30

Calder concerned a state legislature's intervention in a traditional private-law dispute. The case arose out of the probate proceedings for the estate of a Connecticut man named Normand Morison. In 1779, Morison wrote a will leaving his property to his wife Abigail and her heirs. See 8 The Documentary History of the Supreme Court of the United States, 1789–1800, p. 89 (M. Marcus ed. 2007). Soon after Morison wrote his will, he and Abigail had a son. Ibid. When the son was young, Morison died. Ibid. Abigail started the probate process so that she could inherit Morison's property as his will promised. Ibid. But the probate judge held up the process because he wanted to check whether the birth of their son affected the will's validity. Ibid. At the time, Abigail did not mind the delay because the default intestacy rules would have given the property to her and her son anyway. Id., at 89–90.

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