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Constitutional Law • Full Faith and Credit
CONLAW#052
Legal Definition
Courts in one state must give full faith and credit to judgments of courts in another state, so long as: (1) the court that rendered judgment had personal and subject matter jurisdiction, (2) the judgment was on the merits, and (3) the judgment was final.
Plain English Explanation
The Full Faith and Credit Clause requires states to respect court judgments from other states. This prevents losing parties from relitigating the same case in a different state just because they lost the first time.
For the judgment to be binding, the first court must have had proper jurisdiction over the parties and the subject matter of the dispute. The case must have also reached a final judgment on the merits - not dismissed on a technicality before trial.
The rationale is that it would be unfair and inefficient to let parties "shop around" for a favorable judgment by filing in multiple states. Once a court fully and fairly resolves a dispute, other states should accept that resolution.
For the judgment to be binding, the first court must have had proper jurisdiction over the parties and the subject matter of the dispute. The case must have also reached a final judgment on the merits - not dismissed on a technicality before trial.
The rationale is that it would be unfair and inefficient to let parties "shop around" for a favorable judgment by filing in multiple states. Once a court fully and fairly resolves a dispute, other states should accept that resolution.
Hypothetical
Hypo 1: Bob gets a loan from Sam in Hypofornia and agrees to pay it back in a year. A year passes, and Bob doesn't pay back. Sam sues Bob in Hypofornia, and the court decides Bob has to pay the loan back with interest. Bob then moves to New Hypoland and refuses to pay, claiming the court in New Hypoland should decide again. Result: The court in New Hypoland must recognize the Hypofornia court's decision because it had jurisdiction, the decision was based on the loan's merits, and it was final. Bob has to pay Sam according to the Hypofornia court's ruling.
Hypo 2: Bob sues Sam in Hypofornia for a breach of contract. The court decides in favor of Sam before going to a full trial because Bob didn't present enough evidence. Bob then tries to sue Sam again in New Hypoland for the same contract issue. Result: New Hypoland's court refuses to hear the case because the Hypofornia court's decision was on the merits and final, so Full Faith and Credit Clause applies. Bob cannot sue Sam again for the same issue.
Hypo 3: Bob sues Sam in Hypofornia for damage to his car, but the Hypofornia court actually has no power over Sam because Sam lives and works in New Hypoland and has never been to Hypofornia. The court erroneously makes a judgment in favor of Bob. Bob tries to enforce this judgment in New Hypoland. Result: The rule does not apply because the Hypofornia court lacked personal jurisdiction over Sam. New Hypoland does not have to enforce the judgment.
Hypo 4: Sam sues Bob in Hypofornia for breach of a software contract, but the case is dismissed on procedural grounds without examining the facts (such as failing to file the lawsuit within a certain time frame). Sam then tries to sue Bob again in New Hypoland for the same issue, hoping to get the case heard on its merits. Result: The rule does not apply because the original judgment was not on the merits of the case. The dismissal for procedural reasons in Hypofornia does not necessarily prevent Sam from suing Bob in New Hypoland.
Hypo 5: Bob sues Sam in Hypofornia over a property dispute, and the court issues a temporary injunction against Sam until a full trial can be held. Before the trial happens, Bob tries to enforce this temporary injunction in New Hypoland. Result: The rule does not apply because the Hypofornia court's decision was not final; it was a temporary measure awaiting a full trial. New Hypoland does not have to respect the temporary injunction.
Hypo 2: Bob sues Sam in Hypofornia for a breach of contract. The court decides in favor of Sam before going to a full trial because Bob didn't present enough evidence. Bob then tries to sue Sam again in New Hypoland for the same contract issue. Result: New Hypoland's court refuses to hear the case because the Hypofornia court's decision was on the merits and final, so Full Faith and Credit Clause applies. Bob cannot sue Sam again for the same issue.
Hypo 3: Bob sues Sam in Hypofornia for damage to his car, but the Hypofornia court actually has no power over Sam because Sam lives and works in New Hypoland and has never been to Hypofornia. The court erroneously makes a judgment in favor of Bob. Bob tries to enforce this judgment in New Hypoland. Result: The rule does not apply because the Hypofornia court lacked personal jurisdiction over Sam. New Hypoland does not have to enforce the judgment.
Hypo 4: Sam sues Bob in Hypofornia for breach of a software contract, but the case is dismissed on procedural grounds without examining the facts (such as failing to file the lawsuit within a certain time frame). Sam then tries to sue Bob again in New Hypoland for the same issue, hoping to get the case heard on its merits. Result: The rule does not apply because the original judgment was not on the merits of the case. The dismissal for procedural reasons in Hypofornia does not necessarily prevent Sam from suing Bob in New Hypoland.
Hypo 5: Bob sues Sam in Hypofornia over a property dispute, and the court issues a temporary injunction against Sam until a full trial can be held. Before the trial happens, Bob tries to enforce this temporary injunction in New Hypoland. Result: The rule does not apply because the Hypofornia court's decision was not final; it was a temporary measure awaiting a full trial. New Hypoland does not have to respect the temporary injunction.
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