Watkins v. Conway

Background

Watkins held a $25,000 tort judgment obtained in Florida on October 5, 1955. More than five years later he sued to enforce that judgment in Georgia, but Georgia’s law (§3-701) bars suits on foreign judgments brought more than five years after the judgment was obtained. The Georgia trial court and the Georgia Supreme Court entered judgment for the debtor, and the Supreme Court of the United States reviewed that decision.

Reasoning

The Court addressed whether Georgia’s shorter time limit for out-of-state judgments violates the Full Faith and Credit or Equal Protection Clauses of the Constitution. The Court accepted Georgia’s interpretation that the five-year clock runs from the date of the most recent revival of the foreign judgment, not the original judgment date. Because Florida law allows revival of its judgments and has a much longer limitation period, Watkins could revive his Florida judgment and then sue in Georgia within five years of that revival. The Court concluded Georgia’s statute, as interpreted, honors the judgment State’s law and therefore does not unconstitutionally discriminate.

Real world impact

The ruling means creditors holding judgments from other States must watch the law of the State that issued the judgment and may need to revive that judgment there before suing elsewhere. If the judgment State bars revival, a different outcome could follow, but where revival is possible, Georgia will defer to the original State’s timing rules. This decision affirms the Georgia courts’ reading rather than striking down the statute.

Dissents or concurrances

Mr. Justice Douglas dissented. The opinion does not state his reasons in the published text, but his separate view indicates disagreement with the Court’s disposition.