Kernrechtsfrage
Whether Swiss authorities had international jurisdiction to order official administration of the estate based on the decedent’s last domicile.
Extrahierter Entscheid
Swiss authorities were competent because the decedent’s last domicile was found to be in Geneva, not Florida.
Extrahierte Begründung
The court upheld the cantonal findings on domicile and held that the appellants failed to show arbitrariness. The decedent had lived in Geneva from 2003 until her death, and the alleged U.S. ties did not make the foreign domicile finding untenable under Art. 20 and 86 LDIP.