1. In Lacks, the husband won a judgment of divorce even though he apparently failed to meet the residence requirement of the New York divorce law. Despite this defect, the Court of Appeals refused to allow the wife to vacate the judgment for lack of subject-matter jurisdiction. Can you explain the distinction that the court drew between “the jurisdictioncompetence issue” and the “substantive elements in a cause of action”? How significant was the court’s observation that the word “jurisdiction” did not appear in the divorce statute upon which the wife relied? One commentator has argued that jurisdictional statutes are tied to a court’s “raw” authority, while merits issues concern “who can sue whom.” Wasserman, Jurisdiction, Merits, and Procedure: Thoughts on a Trichotomy, 102 Nw. U. L. Rev. 1547, 1547–48 (2008). To what extent does this distinction help to explain the result in Lacks?