Wyman v. Newhouse
93 F.2d 313 (1937)
Rule of Law:
A judgment obtained in a sister state is not entitled to full faith and credit in another state if the court that issued the judgment acquired personal jurisdiction over the defendant by fraudulently enticing them into that jurisdiction for the sole purpose of service of process.
Facts:
- Appellant and Appellee, both married at the time, were residents of Florida and New York, respectively, and had engaged in a multi-year extramarital affair.
- While Appellee was in Salt Lake City, Appellant telegraphed him, referencing a home illness and asking him to visit her in Florida.
- Upon Appellee's return to New York, Appellant sent a letter claiming her mother was dying in Ireland, she was leaving the U.S. permanently, and she desperately needed to see him one last time.
- In a subsequent phone call, Appellant repeated these claims in a distressed manner, leading Appellee to agree to fly to Florida to see her.
- Before his trip, Appellee received an endearing letter from Appellant and telegraphed her to arrange accommodations for them to share.
- Immediately upon Appellee's arrival at the Miami airport, a deputy sheriff served him with process for a $500,000 lawsuit filed by Appellant.
- Appellant was present at the airport with her sister, and a photographer was also there attempting to take Appellee's picture.
- Appellant never went to Ireland, and her claims of her mother's illness and her intent to leave the country were false representations made to lure Appellee into Florida.
Procedural Posture:
- Appellant initiated a lawsuit against Appellee in a Florida state court.
- After being served in Florida, Appellee failed to appear, and a default judgment was entered against him.
- Appellant filed a new action in a New York court to enforce the Florida default judgment.
- Appellee answered the New York complaint by asserting as a defense that he was fraudulently enticed into the Florida jurisdiction.
- In the New York action, Appellant's motion to strike the defense and for summary judgment was denied by the trial court.
- The New York trial court then granted Appellee's motion to dismiss the complaint.
- Appellant, the plaintiff from the Florida action, appealed the dismissal to the U.S. Court of Appeals for the Second Circuit.
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Issue:
Does the Full Faith and Credit Clause of the U.S. Constitution require a state court to enforce a default judgment from a sister state when the defendant was fraudulently induced to enter the sister state's jurisdiction for the sole purpose of being served with process?
Opinions:
Majority - Manton, Circuit Judge
No. A judgment is not entitled to full faith and credit where the jurisdiction of the court rendering it was obtained by fraud. The Full Faith and Credit Clause requires that a judgment be given the same effect in a sister state as it would have in the state where it was rendered. In this case, the facts establish that Appellee was lured into Florida by Appellant's fraudulent misrepresentations for the sole purpose of being served with process. Such fraudulent service would likely be vacated in Florida. A fraud affecting the jurisdiction of the court is equivalent to a lack of jurisdiction, rendering the judgment null and void. Therefore, Appellee can raise the fraudulent procurement of jurisdiction as a defense against the enforcement of the Florida judgment in New York, and he is not required to challenge the judgment in Florida first.
Analysis:
This case solidifies a significant equitable exception to the Full Faith and Credit Clause, which generally mandates interstate recognition of court judgments. The ruling establishes that the constitutional requirement of recognizing sister-state judgments does not protect a judgment procured through jurisdictional fraud. It affirms that a defendant may collaterally attack a judgment in an enforcement action by proving they were deceitfully lured into the rendering jurisdiction. This precedent protects defendants from abuse of process across state lines and upholds the principle that a court's personal jurisdiction must be acquired through legitimate, non-fraudulent means.
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