Florida Court Holds It Can Indirectly Force a Beneficiary to Divest Property under Romanian Law- Indirect Probate of Foreign Realty?

Many people in West Palm Beach have property outside of Florida, some even   outside of the country. What happens with that type of property since generally a state probate court does not have jurisdiction over real property situated in another state or country? How is such property administered? A recent Florida case saw a Florida court order that the Florida personal representative should hold the share of a beneficiary in an intestate Florida estate in a restricted account until that beneficiary does what the Court ordered even though some of the property was outside of Florida. 

1. As I said the general rule is that the state court would not have jurisdiction over outside the state real property and whichever jurisdiction was in the locality of the property would administer what is called an ancillary probate. Keep in mind, these laws may still simply order that the terms of the last will and testament are followed, it may make procedurally very little difference but not always as this recent Florida case shows.
2. The First DCA authored this opinion on March 18, 2015 in the case of Ciungo v. Bulea In Re Estate of Victoria Ciungu which you can read in its entirety here.
3. In this case there was Romanian property and two children of parents who had died intestate in Florida where they resided. The question became what to do with the Romanian property and one party (the beneficiary not the other sibling who was Personal Rep/ co-beneficiary) asked the court to enforce an oral agreement by the siblings (which was unlikely anyways because there was alot of in fighting between the siblings) and the court said no, hold all the property of the beneficiary in an account until they agree to it being devised under Romania law.
4. Remember this was an intestate estate so what to do with the decedents property depends on which law is applied, so the Courts point was that Romanian property gotta divest it under Romanian law.
5. The Court later vacated the order stating that it held no jurisdiction over the property then reversed again holding ultimately that the court had long recognizd that in personam (personal) jurisdiction over the beneficiary gave them the right to order them to devise the property as the law saw fit.

Do you agree? What is the point of the Court not having jurisdiction over the property if it can just twist people’s arms until the property is property divested under their view of things? Does this effect non-Floridian beneficiaries differently in that the court has limited (specific) jurisdiction over them rather than a more general jurisdiction that a Florida resident would have?