What is the test for having in rem jurisdiction in a marital dissolution action?

In addition to personal and subject matter jurisdiction, a court presiding over a marital dissolution action must possess " in rem jurisdiction over the marital res' to terminate marital status." (Muckle v. Superior Court (2002) 102 Cal.App.4th 218, 225, 125 Cal.Rptr.2d 303.) This requirement is expressed in Family Code section 2320, subdivision (a), which provides as relevant here that "a judgment of dissolution of marriage may not be entered unless one of the parties to the marriage has been a resident of this state for six months and of the county in which the proceeding is filed for three months next preceding the filing of the petition."