Watkins v. Conway
1966 U.S. LEXIS 76, 87 S. Ct. 357, 385 U.S. 188 (1967)
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Rule of Law:
A state's statute of limitations that applies a shorter period to foreign judgments than to domestic judgments does not violate the Full Faith and Credit or Equal Protection Clauses of the Federal Constitution if the foreign judgment can be revived in the originating state and subsequently sued upon in the forum state.
Facts:
- Appellant Watkins initiated a tort action against Appellee Conway in a circuit court of Florida.
- On October 5, 1955, the Florida court rendered a $25,000 judgment in favor of Watkins.
- Five years and one day after the Florida judgment, Watkins filed suit upon this judgment against Conway in a superior court of Georgia.
- Conway asserted § 3-701 of the Georgia Code as a defense, which requires all suits upon judgments obtained out of state to be brought within five years.
- Florida law provides a 20-year statute of limitations for its domestic judgments and allows for their revival.
- Georgia’s interpretation of its statute permits a plaintiff to return to the original judgment state, revive the judgment, and then return to Georgia to file suit within five years of that revival.
Procedural Posture:
- Watkins brought a tort action against Conway in a circuit court of Florida (trial court/court of first instance).
- The Florida circuit court rendered a $25,000 judgment for Watkins.
- Watkins sued Conway upon this Florida judgment in a superior court of Georgia (trial court/court of first instance).
- The Georgia superior court granted summary judgment for Conway, rejecting Watkins' contention that Georgia Code § 3-701 violated the Full Faith and Credit and Equal Protection Clauses of the Federal Constitution.
- Watkins, as appellant, appealed this decision to the Georgia Supreme Court.
- The Georgia Supreme Court affirmed the lower court's ruling, also rejecting Watkins' constitutional challenge to § 3-701.
- The United States Supreme Court noted probable jurisdiction to review the case.
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Issue:
Does a Georgia statute of limitations, which mandates suits upon foreign judgments be brought within five years while allowing longer periods for domestic judgments, violate the Full Faith and Credit Clause or the Equal Protection Clause of the Fourteenth Amendment, given that the foreign judgment can be revived in its originating state and then re-filed in Georgia?
Opinions:
Majority - Per Curiam
No, the Georgia statute of limitations, as interpreted by Georgia courts, does not violate the Full Faith and Credit or Equal Protection Clauses. The Court reasoned that the Georgia statute bars suits on foreign judgments only if the plaintiff cannot revive the judgment in the state where it was originally obtained. Because Watkins could return to Florida, where judgments have a 20-year limitation and can be revived, and then sue in Georgia within five years of the revival, the Georgia statute did not discriminate against the Florida judgment. Instead, Georgia's construction of its statute honored and gave effect to Florida law regarding the validity and revivability of its own judgments, thereby ensuring full faith and credit and avoiding invidious discrimination.
Dissenting - William Douglas
Mr. Justice Douglas dissents.
Analysis:
This case is significant for clarifying the scope of the Full Faith and Credit Clause when state statutes of limitations differ between foreign and domestic judgments. It establishes that a state can impose a shorter limitation period on foreign judgments without violating constitutional principles, provided a procedural avenue (like judgment revival) exists in the originating state to maintain the judgment's validity. This ruling prevents forum states from unduly burdening the enforcement of judgments from other states, as long as the judgment creditor has a viable path to keep their judgment alive and enforceable. It underscores the principle that states must respect the validity of sister-state judgments as determined by the laws of the originating state.
