D'Arcy v. Ketchum
52 U.S. 165, 13 L. Ed. 648, 11 How. 165 (1851)
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Rule of Law:
A judgment obtained in a state court against a defendant who was not served with process and did not appear in the proceeding is not entitled to full faith and credit in the courts of another state.
Facts:
- George H. Gossip and James D’Arcy were partners in a business named Gossip & Co. and were jointly indebted to Ketchum, Rogers, and Bement.
- Ketchum, Rogers, and Bement filed a lawsuit against both Gossip and D’Arcy in a New York state court to recover the debt.
- Gossip was personally served with process in New York.
- D’Arcy was a citizen and resident of Louisiana and was never served with process, nor did he appear in the New York court.
- Under a New York statute, if one of several joint debtors is served, a judgment can be entered against all of them.
- The New York court, following this statute, entered a joint judgment against both Gossip and D'Arcy for the full amount of the debt.
Procedural Posture:
- Ketchum, Rogers, and Bement sued D’Arcy in the U.S. Circuit Court for the District of Louisiana, seeking to enforce the New York judgment.
- D'Arcy filed a peremptory exception, arguing that the New York judgment was not a valid basis for a suit against him in Louisiana.
- The Circuit Court overruled D'Arcy's exception and, treating the New York judgment as conclusive, rendered judgment against D'Arcy.
- D'Arcy brought the case to the U.S. Supreme Court on a writ of error.
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Issue:
Does the Full Faith and Credit Clause of the U.S. Constitution require a court in one state to enforce a personal judgment from another state against a defendant who was not served with process and did not appear in the original case, even if the judgment is valid under the laws of the state where it was rendered?
Opinions:
Majority - Mr. Justice Catron
No. A judgment from a state court does not have binding force in another state against a defendant who was not served with process and did not make a voluntary appearance. The Full Faith and Credit Clause and its implementing statute, the Act of 1790, were intended to give conclusive effect to validly rendered judgments, but they do not eliminate the fundamental requirement of personal jurisdiction. The court reasoned that international law has always held that a judgment against a person is void if that person was not served with process or given a day in court. The framers of the Constitution and Congress did not intend to overthrow this established principle. Therefore, a New York statute allowing a judgment against an unserved joint debtor cannot extend its jurisdiction to bind a citizen of Louisiana in Louisiana's courts. To enforce such a judgment would be an 'illegitimate assumption of power'.
Analysis:
This case establishes a critical limitation on the Full Faith and Credit Clause, clarifying that it does not compel states to enforce judgments rendered without personal jurisdiction. It affirms the principle that a court's authority is geographically limited and that due process requires notice and an opportunity to be heard for a judgment to be valid against a person. This decision became a foundational pillar for the modern law of personal jurisdiction, protecting non-resident defendants from being bound by litigation in forums with which they have no connection. It ensures that 'full faith and credit' applies only to constitutionally valid judgments, not to any judgment a state court might issue under its local laws.
