Hartford Life Insurance v. Johnson

Background

A life insurance company sued over a policy lost in Missouri courts and asked the U.S. Supreme Court to review the Missouri high court’s judgment. The company argued Missouri failed to give full faith and credit to a later Connecticut court decree and to the company’s Connecticut charter, both claimed to protect the company’s rights under the Constitution. The Connecticut decree was entered after the trial and was never pleaded or introduced at the Missouri trial; the charter was introduced, but no Connecticut law or decision interpreting it was offered.

Reasoning

The central question was whether the Supreme Court could review Missouri’s final decision on the company’s claim that a constitutional requirement (full faith and credit) was denied. The Court explained that it may review state-court decisions only when the federal claim was properly and timely presented in the state courts by pleading, motion, or other appropriate step. Because the Connecticut decree was not part of the trial record and the company did not supply Connecticut law construing its charter, the Missouri courts did not rule on the federal question in a way that gave this Court jurisdiction. The Supreme Court therefore dismissed the writ for lack of jurisdiction.

Real world impact

This ruling is procedural: it limits when federal review is available. Parties must present out‑of‑state judgments, charters, or laws at trial and supply supporting proof if they want a federal question preserved for review. The decision does not rule on the insurance dispute’s merits, only that federal review was not properly opened here.