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Baker v. General Motor Corporation

    Brief Fact Summary
    Following an injunction issued in one state court prohibiting a former employee from testifying as a witness, Baker (Plaintiff) subpoenaed the same former employee to appear as a witness in another state in litigation against the same employer, General Motors Corporation (Defendant).

    Synopsis of Rule of Law
    Orders commanding action or inaction may be denied enforcement in a sister state when the intention is to accomplish an official act within the exclusive province of that other state or interfere with litigation over which the ordering state has no authority.

    Facts
    In settlement of claims arising from the discharge of Elwell, a former employee of General Motors Corporation (Defendant), a state court in Michigan issued a permanent injunction barring Elwell from testifying, without the prior written consent of GM (Defendant), as a witness of any kind in any litigation that involved Defendant.  However, Defendant agreed separately that if Elwell were ordered to testify by a court, such testimony would not be actionable.  The Bakers (Plaintiff) brought suit against Defendant in Missouri and subpoenaed Elwell to appear as a witness in their suit.  The federal district court in Missouri allowed Plaintiff to depose Elwell and call him as a witness at trial.  Relying on the Full Faith and Credit Clause, the Eighth Circuit reversed, ruling that the testimony should not have been admitted.  The Supreme Court granted review.

    Issue
    May orders commanding action or inaction be denied enforcement in a sister state when the intention is to accomplish an official act within the exclusive province of that other state or interfere with litigation over which the ordering state has no authority?

    Held
    (Ginsburg, J.)  Yes.  Orders commanding action or inaction may be denied enforcement in a sister state when the intention is to accomplish an official act within the exclusive province of that other state or interfere with litigation over which the ordering state has no authority.  In the present case, the Michigan decree ordering the injunction cannot determine evidentiary issues in a lawsuit brought by parties who were not subject to the jurisdiction of the Michigan court.  The Full Faith and Credit Clause mandates recognition only of dispositions that Michigan has the authority to order.  A Michigan decree cannot command obedience somewhere else on a matter the Michigan court lacks authority to resolve.  Reversed.

    Concurrence
    (Scalia, J.)  It has been established that the judgment of a state court cannot be enforced out of state by an execution issued within it.

    (Kennedy, J.)  The case is controlled by well-settled full faith and credit principles that render the majority’s extended analysis unnecessary.  Courts do not need to give a prior judgment any additional force or effect than the issuing state gives it.  Since the Bakers (Plaintiff) were not parties to the Michigan proceedings and had no opportunity to litigate any of the issues presented, it appears that Michigan law would not treat them as bound by the judgment.

    Discussion
    The Court reached its decision by relying on precedent.  Earlier cases considered the transfer of title to land in another state to be an “official act within the exclusive province†of the situs state.  However, the Court made the point that there is no “roving ‘public policy’ exception†to judgment recognition under the Full Faith and Credit Clause.


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