The validity of judgments or decrees in States other than those in which they are obtained depends upon the court which rendered them having obtained jurisdiction. -In order to obtain jurisdiction in actions in rem, the res must be located in the State. In all actions service of notice of the commencement of the suit must be had upon the defendants. In actions in rem this service need not be actual, but may be constructive, that is, by publication In actions in personam, however, actual service is required. Mere constructive service will not warrant a personal judgment or decree which may be sued upon in another jurisdiction. This doctrine is carefully laid down in Pennoyer v. Neff.13 In its opinion in this case the court say: "It is in virtue of the Staters jurisdiction over the property of the non-residents situated within its limits that its tribunals can inquire into that non-resident's obliigations to its own citizens, and the inquiry can then be carried only to the extent necessary to control the disposition- of the property. If the non-residents have no property in the State, there is nothing upon which the tribunals can adudicate. . . . "Where a party is within a territory, he may justly be subjected to its process, and bound personally by the judgment pronounced on such process against him. Where he is not within such territory, and is not personally subject to its laws, if on account of his supposed or actual property being within the ritory, process by the local laws may, by attachment, go to compel his appearance, and for his default to appear, judgment may be pronounced against him; such a judgment must, upon general principle-, be deemed to bind him only to the extent of such property, and cannot have the effect of a conclusive judgment in personam, for the plain reason that, except so far as the property is concerned, it is a judgment coram non judice."

12 213 V. s. 366; 29 Sup. Ct. Rep. 397; 53 L. ed. G95. 13 95 U. S. 714; 24 L. ed. 565.

The inability of the courts of one State to effect by their judgments or decisions property having its legal situs in another State is illustrated in the recent case of Fall v. Eastin,14 in which it was held that a deed to a piece of land located in Nebraska made by a commissioner in the State of Washington under the order of a court of that State need not, under the full faith and credit clause, be recognized in the former State. The court point out that had the plaintiff in error obeyed the order of the Washington court and made, as directed, a deed of conveyance, that conveyance would have received recognition in the Nebraska courts. But he having refused to do this, and the deed having been made by a commissioner, the conveyance was to be considered as a part of the proceedings in the court which ordered it, which court was without power to affect the title of real property not within the State. As to this the court quote from Watkins v.. Holman,15 where it is said: "A court of chancery, acting in personam may well declare the conveyance of land in any other State, and may enforce its decree by process against the defendant. But neither the decree itself nor any conveyance under it, except by the person in whom title is vested, can operate beyond the jurisdiction of the court."