Fauntleroy v. Lum

Brief Fact Summary.

Plaintiff sued Defendant for an unpaid gambling debt in Missouri. Defendant argued that the gambling transaction was illegal under Mississippi law.

Synopsis of Rule of Law.

Under Article IV, § 1 of the Constitution, the credit, validity, and effect of a judgment of a state court is the same in every other court in the United States.

Facts.

In Mississippi, Defendant entered a gambling transaction on cotton futures with Plaintiff but refused to pay Plaintiff when he lost the bet. Plaintiff sued Defendant in Missouri to enforce payment of the debt. Defendant argued that the gambling transaction was illegal and thus unenforceable under Mississippi law.

Issue.

Must the Mississippi court uphold the judgment of the Missouri court against the Defendant?

Held.

Yes, the Mississippi court must uphold the judgment of the Missouri court. The Mississippi judgment is reversed.

Dissent.

Justice White

Justice White argued that the Full Faith and Credit Clause does not require a state to adopt a previous judgment regarding a set facts that took place within that state and which that state had determined to be illegal conduct.

Discussion.

The Court determined that the judgment against the Defendant in Missouri was conclusive and could not be overturned by a Mississippi court without violating Art. IV, § 1 of the Constitution. The Court further noted that one state could not challenge another state’s judgment on the grounds of mistaken law, but could challenge the judgment on the basis of mistaken jurisdiction. However, jurisdiction was not disputed in this case.