During the probate proceedings, Smith declared bankruptcy in California and was awarded $474 million as a sanction for alleged misconduct. In 2002, the bankruptcy judgment was vacated and her award was reduced to $88 million in a Federal District Court in California. In December 2004, a three-judge panel of the United States Court of Appeals for the Ninth Circuit vacated the District Court decision under the probate exception, ruling that the federal courts lacked subject matter jurisdiction over state probate matters. The Ninth Circuit decision also affirmed the primacy of Texas Probate decision which determined that no misconduct had taken place and that Smith was not one of J. Howard Marshall's heirs. However, on May 1, 2006, the Supreme Court in "Marshall v. Marshall" reversed the Ninth Circuit's decision regarding the probate exception, allowing Smith another opportunity to pursue her claims in federal court. The case was remanded to the Ninth Circuit for adjudication of the remaining appellate issues. On June 25, 2009, the same three-judge panel of the United States Court of Appeals for the Ninth Circuit heard oral arguments on the remaining appellate issues. On March 19, 2010, the United States Court of Appeals for the Ninth Circuit issued its second opinion on remand, finding in favor of E. Pierce Marshall, that the California Bankruptcy Court did not have jurisdiction and the California Federal District Court was precluded from reviewing matters already decided in the Texas Probate Court.