Lexis Nexis - Case Brief

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Law School Case Brief

Fauntleroy v. Lum - 210 U.S. 230, 28 S. Ct. 641 (1908)

Rule:

Under U.S. Const. art. IV, § 1, the judgment of a state court has the same credit, validity, and effect in every other court in the United States, which it had in the state where it was pronounced, and whatever pleas would be good to a suit thereon in such state, and none others, can be pleaded in any other court of the United States.

Facts:

Plaintiff and defendant, Mississippi citizens, entered into an illegal contract under Mississippi law. Plaintiff then obtained an arbitration award against defendant in Mississippi pursuant to their contract, but sought to enforce the award in Missouri where defendant was temporarily located and served. The Missouri court entered judgment in favor of the plaintiff, who later sought to enforce the judgment in Mississippi. The supreme court of Mississippi ruled that their courts are not required to give full faith and credit to a judgment plaintiff obtained against defendant in Missouri because the action was unenforceable in Mississippi.

Issue:

Does the Constitution require the Mississippi courts to enforce a Missouri judgment?

Answer:

Yes.

Conclusion:

The Supreme Court reversed, holding that U.S. Const. art. IV, § 1 obligated the Mississippi courts to enforce the Missouri judgment even if the Missouri judgment was based on a misapprehension of Mississippi law where there was no question the Missouri court had jurisdiction when it rendered judgment.

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