Baker v. General Motors Corporation
522 U.S. 222 (1998)
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Rule of Law:
The Full Faith and Credit Clause does not compel a court to enforce another state's injunction that purports to control evidentiary matters or witness competency in litigation involving parties who were not subject to the jurisdiction of the issuing court.
Facts:
- Ronald Elwell, a long-time engineering analyst for General Motors (GM), specialized in studying vehicular fires and often assisted GM's lawyers in product liability litigation.
- After his employment relationship with GM soured, Elwell was deposed in a Georgia product liability case against GM and gave testimony that was damaging to the company, contradicting his prior in-house expert testimony.
- Following this deposition, Elwell sued GM in a Michigan state court for wrongful discharge, and GM filed a counterclaim.
- Elwell and GM settled their lawsuit, and as part of the settlement, a Michigan court entered a stipulated permanent injunction prohibiting Elwell from testifying in any litigation involving GM without its prior written consent.
- A separate, private settlement agreement specified that if a court ordered Elwell to testify, GM would not take action against him for violating the injunction.
- Beverly Garner died in Missouri when the 1985 Chevrolet S-10 Blazer she was in caught fire following a highway accident.
- Garner's sons, Kenneth and Steven Baker, believing a faulty fuel pump caused the fire, initiated a wrongful-death product liability action against GM.
Procedural Posture:
- The Bakers sued General Motors (GM) in a Missouri state court for wrongful death.
- GM, the defendant, removed the action to the U.S. District Court for the Western District of Missouri, a federal trial court.
- During the litigation, the District Court granted the Bakers' request to allow the testimony of Ronald Elwell, over GM's objection that a Michigan state court injunction barred it.
- A jury found in favor of the Bakers and awarded them $11.3 million in damages.
- GM, as appellant, appealed the judgment to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals reversed the District Court's judgment, holding that Elwell's testimony should have been excluded under the Full Faith and Credit Clause.
- The Bakers, as petitioners, sought and were granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does the Full Faith and Credit Clause require a Missouri federal court to enforce a Michigan state court injunction that prevents a witness from testifying in a Missouri case, where the plaintiffs in the Missouri case were not parties to the Michigan litigation?
Opinions:
Majority - Justice Ginsburg
No. The Full Faith and Credit Clause does not require the Missouri court to enforce the Michigan injunction. While the Clause demands that the preclusive effects of a judgment be honored between the parties to that judgment, it does not permit one state to control the evidentiary proceedings of another state's courts, especially in a case involving different parties. Michigan's judgment is claim preclusive between Elwell and GM, but Michigan lacks the authority to determine for a Missouri court what witnesses are competent or what evidence is admissible in a separate case brought by strangers to the Michigan litigation, like the Bakers. Enforcement measures do not travel with a judgment; the authority to sanction a violation of an injunction generally remains with the court that issued it. Therefore, Michigan cannot command obedience from the Missouri court on an evidentiary matter it has no authority to resolve.
Concurring - Justice Scalia
No. The Full Faith and Credit Clause does not require a Missouri court to enforce the Michigan injunction. The Clause and its implementing statute establish a rule of evidence, not jurisdiction, meaning a sister state's judgment must be accepted as conclusive proof of the matter adjudged, but it does not have to be enforced directly. A court in one state is not obliged to execute an injunction from another state by preventing a witness from testifying, just as it is not obliged to hold that witness in contempt. To be enforced, the Michigan decree would have to be made a judgment in Missouri, which was not done here; GM simply asked the Missouri court to directly execute the Michigan injunction.
Concurring - Justice Kennedy
No. The Missouri court is not required to give the injunction preclusive effect because the courts of the issuing state, Michigan, would not do so against the Bakers. The proper first step in a Full Faith and Credit analysis is to determine the preclusive effect of the judgment in the state where it was rendered. Under Michigan law, issue preclusion (collateral estoppel) requires that the parties be the same or in privity, which is not the case here as the Bakers were not parties to the Elwell-GM litigation. Since Michigan courts would not bind the Bakers to the injunction, no other court is required by the Full Faith and Credit Clause to give it greater effect. This resolves the case without needing to create broad new exceptions to the Full Faith and Credit Clause, as the majority opinion does.
Analysis:
This decision clarifies a significant limit on the Full Faith and Credit Clause, establishing that its command does not extend to enforcing sister-state injunctions that interfere with the procedural and evidentiary autonomy of a forum court. By distinguishing between the preclusive effect of a judgment on the original parties and the impermissible control over proceedings involving non-parties, the Court protects the integrity of a court's process to determine witness competency and the admissibility of evidence. The ruling prevents parties from using private settlements and consent decrees in one jurisdiction to suppress evidence and shield themselves from liability in future litigation brought by others in different jurisdictions. It affirms that a court's power is generally confined to the parties and controversies before it.
