Baker v. General Motors Corp.
Citation and Court
522 U.S. 222 (1998), Supreme Court of the United States
Facts
As part of a settlement with General Motors, Ronald Elwell — a former GM engineer — agreed to a Michigan court injunction barring him from testifying against GM in future litigation. When a Missouri lawsuit against GM required Elwell’s testimony, the Bakers subpoenaed him. GM argued that Missouri courts must give full faith and credit to the Michigan injunction barring Elwell’s testimony.
Issue
Whether the Full Faith and Credit Clause requires Missouri courts to honor a Michigan court’s injunction preventing a witness from testifying in out-of-state litigation.
Holding
The Full Faith and Credit Clause does not require Missouri to enforce the Michigan injunction barring Elwell’s testimony; a state cannot, through an injunction, control the conduct of judicial proceedings in another state’s courts.
Rule / Doctrine
The Full Faith and Credit Clause requires states to honor other states’ judgments and statutes, but a state cannot export its own injunctive decrees to govern the proceedings of courts in another state. A state court injunction operates in personam and cannot dictate what evidence another state’s courts may receive in their own proceedings.
Significance
Baker v. GM clarified an important limit on full faith and credit: while states must enforce sister-state money judgments, they need not allow one state’s courts to control the evidentiary rules or witness availability in another state’s courts. It protects the sovereignty of each state over its own judicial proceedings.