Tennessee Coal, Iron & Railroad v. George
233 U.S. 354, 1914 U.S. LEXIS 1255, 34 S. Ct. 587 (1914)
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Rule of Law:
The Full Faith and Credit Clause does not compel a state to refuse jurisdiction over a transitory cause of action created by another state's statute, even if the creating state's statute attempts to restrict venue exclusively to its own courts.
Facts:
- Wiley George was an engineer employed by the Tennessee Coal, Iron and Railroad Company at its steel plant in Jefferson County, Alabama.
- While George was under a locomotive repairing the brakes, a defective throttle allowed steam to leak into the cylinder.
- The steam leak caused the engine to move forward automatically.
- As a result of the engine's movement, George was seriously injured.
Procedural Posture:
- Wiley George brought suit by attachment against Tennessee Coal, Iron and Railroad Company in the City Court of Atlanta, Georgia (trial court), founding his action on § 3910 of the Alabama Code of 1907.
- Tennessee Coal, Iron and Railroad Company filed a plea in abatement, arguing that § 6115 of the Alabama Code restricted such actions to Alabama courts, and thus continuing the case in Georgia would deny full faith and credit to Alabama's public acts.
- The City Court of Atlanta, Georgia, sustained a demurrer to the plea in abatement.
- A judgment was subsequently entered for Wiley George in the City Court of Atlanta.
- The judgment for George was affirmed by the Court of Appeals of Georgia (intermediate appellate court).
- The case was then brought to the Supreme Court of the United States.
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Issue:
Does the Full Faith and Credit Clause of the U.S. Constitution prohibit a state's courts from enforcing a transitory cause of action created by another state's statute when that statute explicitly mandates that such actions "must be brought in a court of competent jurisdiction within the State of Alabama and not elsewhere"?
Opinions:
Majority - Mr. Justice Lamar
No, the Full Faith and Credit Clause does not prohibit Georgia courts from enforcing an Alabama cause of action even if the Alabama statute restricts venue. The Court acknowledged that in some cases, a right and its remedy are so united that the right cannot be enforced except in the manner and before the tribunal designated by the act. However, this rule does not apply to the Alabama Code relating to suits for injuries caused by defective machinery. This statute creates a transitory cause of action, meaning the place of bringing the suit (venue) is not an inseparable part of the cause of action itself. Venue is distinct from the right, and a state cannot create a transitory cause of action and simultaneously destroy the right to sue on it in any court having jurisdiction. The jurisdiction of a court is determined by its own creation and cannot be defeated by the extraterritorial operation of another state's statute, even if that statute created the right of action. The Court referenced its decision in Atchison &c. Ry. v. Sowers, where it affirmed a judgment obtained in Texas based on a New Mexico statute that attempted to restrict venue. The Georgia court was bound to give full faith and credit to the substantial provisions of the Alabama statute that inhered in the cause of action, not to the venue restriction.
Dissenting - Mr. Justice Holmes
Mr. Justice Holmes dissents.
Analysis:
This case significantly clarifies the limits of state power in controlling the enforcement of statutory causes of action in other jurisdictions, particularly regarding venue. It reinforces the principle that procedural rules, like venue, generally do not carry extraterritorial effect under the Full Faith and Credit Clause, unlike substantive rights. The decision ensures that states cannot create rights while simultaneously undermining their enforceability by other competent courts, thereby promoting interstate recognition and uniformity in the application of laws concerning transitory actions. It underlines that the forum state ultimately determines its own jurisdiction.
