Clarke v. Clarke
Citation and Court
178 U.S. 186 (1900), Supreme Court of the United States
Facts
A South Carolina testatrix died leaving a will that directed her personal property to be divided equally among her daughters after a period of investment. South Carolina law treated personal property under a will as distributed immediately; Connecticut, where the property was located, would have treated the property differently under its own succession rules. The South Carolina probate court’s interpretation of the will was challenged when the property was administered in Connecticut.
Issue
Whether Connecticut courts were required under the Full Faith and Credit Clause to accept the South Carolina court’s interpretation of the will and the distribution of personal property located in Connecticut.
Holding
Connecticut was required to give full faith and credit to the South Carolina judgment interpreting the will; Connecticut could not apply its own law to defeat the legal effect of the South Carolina court’s authoritative decree.
Rule / Doctrine
The Full Faith and Credit Clause requires sister states to give the same effect to a state court’s judgment as that judgment has in the rendering state. A state may not apply its own law to defeat or circumvent the legal effect of a duly entered sister-state judgment.
Significance
Clarke v. Clarke is an early Full Faith and Credit case illustrating the clause’s application to judgments regarding the distribution of personal property, reinforcing the constitutional requirement that states honor the dispositive legal determinations of sister-state courts.