Baker v. GMC

522 U.S. 222



Judicial precedent differentiates the credit owed to laws (legislative measures and common law) and to judgments. Credit must be given to the judgment of another state although the forum would not be required to entertain the suit on which the judgment was founded. Although the Full Faith and Credit Clause, U.S. Const. art. IV, § 1, does not compel a state to substitute the statutes of other states for its own statutes dealing with a subject matter concerning which it is competent to legislate, regarding judgments, the full faith and credit obligation is exacting. A final judgment in one state, if rendered by a court with adjudicatory authority over the subject matter and persons governed by the judgment, qualifies for recognition throughout the land. For claim and issue preclusion (res judicata) purposes, in other words, the judgment of the rendering state gains nationwide force.


Petitioner survivors were granted certiorari to review the judgment of the United States Court of Appeals for the Eighth Circuit reversing a judgment against respondent company in a wrongful death action. The Court of Appeals ruled that the testimony of a certain witness should not have been admitted because the district court should have given full faith and credit to a court order from another state enjoining his testimony against the company. The company settled an employment action against it in a Michigan state court by paying money to its former engineering analyst in exchange for an injunction prohibiting the analyst from testifying against the company in subsequent litigation without its consent, unless he was court-ordered to do so. The survivors sued the company for wrongful death in Missouri state court, later removed to federal court. Over the company's objections based on the Michigan injunction, the survivors were allowed to subpoena the analyst for deposition and trial testimony. Judgment was subsequently entered for the survivors, but the court of appeals reversed, ruling that the Full Faith and Credit Clause, U.S. Const. art. IV, § 1, required enforcement of the Michigan injunction, such that the analyst's testimony should have been excluded.


Was a court's admission of a witness's testimony, barred by an injunction, a violation of the Full Faith and Credit Clause of Article IV?




In reversing the court of appeals, the Supreme Court ruled that, although the injunction was claim preclusive between the company and the analyst, it had no control over others. The full faith and credit provision did not apply to evidentiary rulings and did not bar the survivors, non-parties to the Michigan action, from obtaining the analyst's testimony in their Missouri action.
The judgment of the court of appeals was reversed.

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