Roche v. McDonald

Citations: 275 U.S. 449; 48 S. Ct. 142; 72 L. Ed. 365; 1928 U.S. LEXIS 47; 53 A.L.R. 1141Docket: 38

Court: Supreme Court of the United States; January 3, 1928; Federal Supreme Court; Federal Appellate Court

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A writ of error was filed to review a judgment from the Supreme Court of Washington, which was contested on the basis that it failed to grant full faith and credit to a judgment from Oregon. The U.S. Supreme Court dismissed the writ due to lack of jurisdiction but granted a petition for certiorari to examine the case's merits. Roche had obtained a judgment against McDonald in Washington, which was later assigned to him. After McDonald was served in Oregon and failed to respond, a judgment was issued against him there. When Roche attempted to enforce this Oregon judgment in Washington, McDonald countered that it was invalid under a Washington statute that voids judgments after six years. The Washington courts ruled in favor of McDonald, stating the original Washington judgment had expired, rendering the Oregon judgment without legal basis. They concluded that the full faith and credit clause does not require recognition of judgments that would be void under the laws of the recognizing state. The U.S. Supreme Court reiterated that judgments from one state must be recognized in others as long as they were valid in the state where rendered, emphasizing that defenses available in the originating state are applicable elsewhere.

A judgment from one state must be enforced in another state if it is valid where rendered, regardless of conflicting state statutes. This principle is supported by several cases, including Christmas v. Russell, where a promissory note issued in Mississippi was enforced in Kentucky despite Mississippi's statute of limitations. The Mississippi courts could not disregard the Kentucky judgment due to the Full Faith and Credit Clause, as it was valid and conclusive in Kentucky.

In Fauntleroy v. Lum, the original cause of action involved a gambling contract deemed illegal in Mississippi. An arbitration award against the defendant was enforced in Missouri, and the Missouri court did not allow the defendant to contest the legality of the contract. When the defendant appealed in Mississippi against the Missouri judgment, the Mississippi Supreme Court initially upheld the judgment. However, the U.S. Supreme Court reversed this, emphasizing that a state court's judgment must hold the same validity across the United States as it does in the originating state. The judgment cannot be contested on grounds of legal mistakes, but jurisdictional issues may be raised. Since jurisdiction over the Missouri court's ruling was not questioned, the Mississippi court could not invalidate the Missouri judgment based on a misinterpretation of Mississippi law.

The case American Express Co. v. Mullins establishes that a judgment from one state is conclusive and cannot be challenged in another state based on a mistake of law, as affirmed by the full faith and credit clause. In Kenney v. Supreme Lodge, the court ruled that an Illinois statute prohibiting the prosecution of a cause of action from Alabama was incompatible with this clause, emphasizing that judgments must be enforced even if they arise from causes that would be deemed illegal in the enforcing state. The precedent set by Fauntleroy v. Lum further supports that a valid judgment from Oregon must be recognized in Washington despite any state-specific legal issues, such as contravening Washington statutes. The party seeking to challenge the judgment in Washington must have raised these legal defenses in Oregon, as they cannot later dispute the judgment's validity based on a misinterpretation of Washington law. Consequently, the Supreme Court of Washington's judgment is reversed, and the case is remanded for proceedings aligned with this opinion. The writ of error is dismissed, and certiorari is granted.