Union National Bank v. Lamb
1949 U.S. LEXIS 2401, 69 S. Ct. 911, 337 U.S. 38 (1949)
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Rule of Law:
The Full Faith and Credit Clause requires a state to enforce a judgment validly revived in a sister state, provided the rendering court had jurisdiction, even if the forum state's law would not have permitted the original judgment to be revived due to its own statute of limitations.
Facts:
- Union National Bank of Wichita, Kansas (Petitioner) obtained a judgment against Lamb (Respondent) in Colorado in 1927.
- Colorado law allowed for the revival of judgments, and Petitioner revived this Colorado judgment in 1945.
- Lamb was personally served in Missouri during the 1945 Colorado revival proceedings.
- Missouri had statutes limiting the life of a judgment to ten years after its original rendition or revival, and no judgment could be revived after ten years from its rendition.
- These Missouri statutes applied to all judgments, whether rendered by a Missouri court or any other court.
- Petitioner brought suit in Missouri to enforce the revived Colorado judgment.
Procedural Posture:
- Union National Bank of Wichita, Kansas (Petitioner) brought suit in a Missouri state trial court to enforce a judgment that had been revived in Colorado.
- The Supreme Court of Missouri (the state's highest court) reversed, refusing to enforce the revived judgment, holding that Missouri's law governing the limitations of actions applied and that the Full Faith and Credit Clause did not require Missouri to recognize Colorado's more lenient revival policy.
- Petitioner sought to appeal the Missouri Supreme Court's decision to the Supreme Court of the United States.
- The Supreme Court of the United States treated the appeal papers as a petition for certiorari and granted certiorari.
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Issue:
Does the Full Faith and Credit Clause require a state to enforce a judgment that has been validly revived in another state, even if the forum state's law would not have permitted the original judgment to be revived due to its own statute of limitations?
Opinions:
Majority - Mr. Justice Douglas
Yes, the Full Faith and Credit Clause requires a state to enforce a judgment validly revived in another state, even if the forum state's law would not have permitted the original judgment to be revived. The Court found Roche v. McDonald to be dispositive, which held that a valid judgment from a sister state must be given full faith and credit, even if it could not have been obtained or was contrary to the policy of the forum state. This principle extends to revived judgments, emphasizing that the integrity of the judgment cannot be impaired, save for challenges to the rendering court's jurisdiction. The Full Faith and Credit Clause and its implementing statute are designed to resolve clashes of policies between states. The Court distinguished this situation from cases involving a statute of limitations against a cause of action on a judgment (like M’Elmoyle v. Cohen), which do not undermine the judgment's integrity. The Court noted that the Missouri Supreme Court applied Missouri law, not Colorado law, in concluding that the revived judgment was effectively barred. Colorado authorities, such as La Fitte v. Salisbury, suggest that a revived judgment has the effect of a new one. However, because the Missouri court did not fully determine the status of the 1945 judgment under Colorado law or whether the service for its revival satisfied due process, those questions remain open on remand.
Dissenting - Mr. Justice Frankfurter
No, it is not clear whether the Full Faith and Credit Clause requires Missouri to enforce the revived Colorado judgment without first determining whether Colorado's revival proceedings created a new judgment or merely extended the statute of limitations on the old one. Justice Frankfurter agreed that Full Faith and Credit generally mandates respect for sister-state judgments, citing precedents like Christmas v. Russell and Fauntleroy v. Lum. However, he emphasized that states may apply their own statutes of limitations to enforce a foreign judgment (M’Elmoyle v. Cohen). The key distinction, he argued, is whether the Colorado revival proceedings created a new judgment (in which case Roche v. McDonald would apply) or merely extended the limitation period on the original 1927 judgment (in which case M’Elmoyle v. Cohen would apply). He contended that the Missouri Supreme Court's opinion was ambiguous on the effect of the Colorado reviver under Colorado law, likely assuming it merely extended the original judgment's life. Justice Frankfurter believed the Court should not assume a new judgment was created under Colorado law without explicit adjudication, and therefore, the proper course would be to vacate the judgment and remand the case for the Missouri court to first determine the precise effect of the Colorado reviver proceedings under Colorado law.
Analysis:
This case significantly reinforces the expansive reach of the Full Faith and Credit Clause, particularly concerning the enforceability of sister-state judgments, including those that have been revived. It highlights the principle that a state generally cannot refuse to enforce a valid judgment from another state based on its own public policy or procedural rules, such as its statute of limitations on original judgments or revival policies, once that judgment has been validly obtained or renewed. The Court's emphasis on distinguishing between a 'new' judgment and an 'extended' old one, particularly as raised in the dissent, underscores a critical future legal consideration for states grappling with the enforceability of foreign judgments.
