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Dissolution Of Marriage—Jurisdiction Over Nondomiciliary Service Members: Time To Adopt A New Jurisdictional Analysis—In Re Marriage Of Ways, 85 Wn. 2d 693, 538 P.2d 1225 (1975); Wash. Rev. Code § 26.09.030 (1975), Bruce A. Robertson
Washington Law Review
On November 30, 1973, Raymond A. Ways, a member of the United States Navy on active military duty, filed a petition for dissolution of marriage in a Washington superior court. Ways had been stationed in Washington aboard the USS Enterprise (then undergoing repairs at the Puget Sound Naval Shipyard, Bremerton, Washington) since October 1973, but neither he nor his wife had ever been domiciled in Washington. Ways filed his petition in reliance upon R.C.W. § 26.09.030, a statute allowing members of the armed forces stationed in Washington to petition for dissolution of marriage in the state. On February 2, 1974, …