Fauntleroy v. Lum
210 U.S. 230 (1908)

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U.S. Supreme Court

Fauntleroy v. Lum, 210 U.S. 230 (1908)

Fauntleroy v. Lum

No. 215

Argued April 27, 28, 1908

Decided May 18, 1908

210 U.S. 230

Syllabus

A judgment is conclusive as to all the media concludendi, and it cannot be impeached either in or out of the state by showing that it was based on a mistake of law.

A judgment of a court of a state in which the cause of action did not arise, but based on an award of arbitration had in the state in which the cause did arise, is conclusive, and, under the full faith and credit clause of the federal Constitution, must be given effect in the latter state, notwithstanding the award was for a claim which could not, under the laws of that state, have been enforced in any of its courts.

80 Miss. 757 reversed.

The facts are stated in the opinion.

Page 210 U. S. 233

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Primary Holding

A state court must enforce the judgment of another state court that had proper jurisdiction over the case, even if the court that ruled on the case incorrectly applied the law of the state of the court that must enforce it.

Facts

Fauntleroy and Lum participated in a cotton futures transaction in Mississippi. A dispute arose when Lum did not pay the loss on the transaction, and an arbitrator eventually ruled against him. Fauntleroy sued Lum for damages while Lum was temporarily in Missouri, and he received a favorable verdict from the Missouri court as well. However, the Mississippi Supreme Court declined to enforce the Missouri verdict against Lum, who was a Mississippi resident.

Opinions

Majority

  • Oliver Wendell Holmes, Jr. (Author)
  • Melville Weston Fuller
  • David Josiah Brewer
  • Rufus Wheeler Peckham
  • William Henry Moody

The question of whether the Missouri court reached the correct conclusion in the case is immaterial because the judgment was final, and the Missouri court would have expected its judgment to be binding in Mississippi. Any mistake that the court may have made would have been an inadvertent error rather than intentional harm to a Mississippi citizen. All states depend on the cooperation of other states in enforcing their judgments, which is required by the Full Faith and Credit Clause of the Constitution.

Dissent

  • Edward Douglass White (Author)
  • John Marshall Harlan
  • Joseph McKenna
  • William Rufus Day

At the time that the Constitution was adopted, generally accepted principles of comity would not have required states to enforce judgments of other states. There is no foundation for diverging from these principles.

Case Commentary

The Full Faith and Credit Clause of the U.S. Constitution requires that other states recognize and enforce the judgments of other states, following the principle of comity.

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