Baker v. General Motors Corporation

Brief Fact Summary.

Plaintiffs sue GM and attempt to subpoena a former GM employee to testify, even though the former employee is bound to an injunction requiring him not to release confidential information about GM.

Synopsis of Rule of Law.

The Full Faith and Credit Clause does not require one state to enforce an injunction issued by another state when the injunction impermissible controls proceedings over which the first state does not have jurisdiction.

Facts.

Elwell worked for GM for thirty years studying safety, and was occasionally asked to testify as an in-house expert for GM. In 1991, after leaving GM. Elwell was called upon to testify in a case where he gave starkly different testimony during a deposition than he had while he worked at GM. His testimony suggested that GM’s fuel system was inferior to that of other cars. Elwell soon initiated a wrongful discharge action against GM in Michigan county court. GM cross-claimed and the suit resulted in a preliminary injunction keeping Elwell from releasing GM’s confidential information Elwell acquired during his employment. The injunction was to become permanent, but allowed Elwell to testify if called upon without breaking the agreement. In 1991 Beverly Garner was killed in Missouri when she was involved in a crash and her GM vehicle caught fire. Plaintiff Bakers, sons of decedent, brought suit against GM in Missouri state court and sought to subpoena Elwell which the court allowed over GM’s objection. The court found that blocking Elwell’s testimony would violate Missouri public policy and that the injunction could be modified in both Michigan and any other state. Plaintiff Bakers were awarded $11.3 million in damages as a result of Elwell’s testimony. On appeal, the court reversed finding that the Full Faith and Credit Clause required the Missouri trial court to uphold the injunction. The Bakers appealed and the U.S. Supreme Court granted certiorari.

Issue.

Does the Full Faith and Credit Clause require one state to enforce an injunction from another state when the injunction would impermissibly control the proceeding over which the injunction-issuing state has no jurisdiction?

Held.

No, the Full Faith and Credit Clause does not require one state to enforce an injunction from another state when the injunction would impermissibly control the proceeding over which the injunction-issuing state has no jurisdiction. The holding below is reversed and remanded.

Concurring

The court outlines two exceptions to full faith and credit that are too broad: (1) a state can disregard the judgement of another state if it attempts to carry out an official act within the exclusive jurisdiction of another state (2) it is not applicable to injunctions that interfere with litigation over which the ordering court has no authority. The majority could have more simply reached the same conclusion by holding that Plaintiff Bakers were not parties in the first suit and were therefore not subject to Michigan’s jurisdiction or injunction.

Dissent.

Justice Justice Kennedy with Justices O’Connor and Thomas join, concurring in the judgement

The court outlines two exceptions to full faith and credit that are too broad: (1) a state can disregard the judgement of another state if it attempts to carry out an official act within the exclusive jurisdiction of another state (2) it is not applicable to injunctions that interfere with litigation over which the ordering court has no authority. The majority could have more simply reached the same conclusion by holding that Plaintiff Bakers were not parties in the first suit and were therefore not subject to Michigan’s jurisdiction or injunction.

Discussion.

1. The Full Faith and Credit Clause requires all courts to respect the public acts, records, and judicial proceedings of other states.
2. This was codified in 28 U.S.C. § 1738.
3. There is no public policy exception to full faith and credit, and a state must accept the final judgment of another state as if it were their own.
4. Full Faith and Credit, however, does not require a state to adopt another’s practices regarding time, manner, or devices used in enforcing judgements.
5. Injunctions have been denied enforcement when they interfere with actions over which the issuing court has no jurisdiction.
6. Here, the injunction issued by the Michigan court extends too far and impermissibly precludes other courts from calling witnesses.
7. The Michigan court may block Elwell from testifying voluntarily, but it cannot block a subpoena.
8. Therefore the holding below is reversed and remanded.