Union National Bank v. Lamb

1949-05-16

Headline: Court requires states to honor sister-state revived judgments, reversing Missouri and making it harder for a state to refuse enforcement of an out-of-state judgment based on its own revival deadline.

Holding: The Court held that Missouri must give full faith and credit to a Colorado judgment revived in Colorado and cannot refuse enforcement simply because Missouri’s own revival deadline had passed.

Real World Impact:

Requires states to enforce validly revived out-of-state judgments.
Protects creditors who revive judgments in the state that rendered them.
Leaves questions about revival mechanics and service for lower courts to resolve.

Topics: interstate judgment enforcement, out-of-state judgments, statute of limitations, reviving old judgments

Summary

Background

A bank held a Colorado money judgment obtained in 1927 and had that judgment revived in Colorado in 1945 after serving the defendant while the defendant was in Missouri. The bank then sued in Missouri to enforce the revived Colorado judgment. Missouri’s highest court refused to enforce it because Missouri law limits revival of judgments to ten years and, it said, Missouri could apply its own revival rules to foreign judgments.

Reasoning

The Supreme Court addressed whether Missouri had to give full faith and credit to the Colorado judgment. Relying on earlier decisions, the Court said that when a sister State’s court had jurisdiction and rendered a valid judgment, the forum State could not defeat that judgment by applying its own revival rules. The Court reversed Missouri’s refusal to enforce the Colorado revival and treated the question as one governed by the Constitution’s requirement that States respect other States’ judicial decisions.

Real world impact

The ruling means courts must generally enforce out-of-state judgments that were validly revived where rendered, rather than letting local revival time limits automatically block enforcement. The Court also left open two factual and legal questions for the lower courts to decide on remand: whether Colorado’s revival created a new judgment under Colorado law, and whether the service used to revive the judgment satisfied due process.

Dissents or concurrances

Justice Frankfurter (joined by Justices Black and Rutledge in part) would have vacated and remanded for further proceedings, emphasizing uncertainty about Colorado law and whether the revival produced a new judgment.