Union National Bank v. Lamb
United States Supreme Court
337 U.S. 38 (1949)
In 1927, Union National Bank (Union National) (plaintiff) obtained a judgment against Carl Lamb (defendant) in a Colorado court. Lamb never paid the judgment. In 1945, Union National revived the Colorado judgment by obtaining personal service upon Lamb in Missouri. Shortly thereafter, Union National filed an action in Missouri state court to recover on the revived Colorado judgment. Because the judgment was originally won in Colorado, Union National argued that the Full Faith and Credit Clause of the United States Constitution obligated the Missouri court to use Colorado’s rule for reviving judgments. Lamb argued that Missouri law applied and barred enforcement of any judgment more than 10 years old. Lamb claimed that because Union National did not revive the Colorado judgment within 10 years of its rendition in 1927, Union National could not recover on the Colorado judgment in Missouri court. The trial court agreed with Lamb and dismissed Union National’s suit. Union National appealed. The Supreme Court of Missouri affirmed, holding that the Full Faith and Credit Clause did not require Missouri to recognize Colorado’s longer statute of limitations with respect to reviving judgments. The United States Supreme Court granted certiorari to review.
Rule of Law
Holding and Reasoning (Douglas, J.)
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