Gannon (Plaintiff) sought to enforce an Illinois judgment against Britton (Defendant) in Oklahoma and the trial court would not allow Defendant to introduce evidence that the Illinois judgment was the result of extrinsic fraud.
A state court does not have to honor another state’s judgment when that judgment was the result of extrinsic fraud.
When Defendant was sued by Plaintiff in Illinois state court, he did not file a response or appear due to his reasonable reliance on the misrepresentations of Plaintiff’s brother, the real party in interest. The court entered judgment against Defendant and Plaintiff brought an action in Oklahoma to enforce the Illinois judgment. Defendant wished to assert a defense to the judgment, claiming that the Illinois judgment was the result of extrinsic fraud. The Oklahoma court did not allow Defendant to raise the defense, finding that the Full Faith and Credit Clause of the U.S. Constitution required it to enforce the Illinois judgment and prevented it from hearing evidence of fraud. Defendant appealed.
Does the Full Faith and Credit Clause of the U.S. Constitution require a state court to honor another state’s judgment even where it was the result of extrinsic fraud?
(Arnold, J.) No. A state court does not have to honor another state’s judgment when that judgment was the result of extrinsic fraud. If a defense to the judgment would be allowed in the state where it was entered, that defense is also available in an action to enforce that judgment in any other court in the United States. A court may set aside a judgment obtained by fraudulently preventing the defendant from fairly presenting his case. The trial court had the power to hear Defendant’s evidence of extrinsic fraud, and if it found the judgment to have been fraudulently obtained, to refuse to enforce it. Reversed and remanded.
Under the Full Faith and Credit Clause, a state must afford the same credit to judgments from other states as those judgments would warrant in the states in which they were entered. A state is not required to give more credit to another state’s judgment than the judgment would get in the issuing state. A party may collaterally attack the validity of the out-of-state judgment in the same way he would be able to attack it in the issuing state. If the collateral attack is unsuccessful, the judgment must be enforced.