Huntington v. Attrill
Citation and Court
146 U.S. 657 (1892), Supreme Court of the United States
Facts
Huntington obtained a judgment in New York against Attrill under a New York statute that made directors of corporations personally liable for false corporate reports. Attrill moved to Maryland, and Huntington sought to enforce the New York judgment there. Attrill argued the judgment was based on a “penal” statute and therefore could not be enforced in Maryland under the traditional rule that courts will not enforce the penal laws of other sovereigns.
Issue
Whether a New York statute imposing personal liability on corporate directors for false reports is “penal” in the conflict-of-laws sense, such that Maryland courts need not give it full faith and credit.
Holding
The New York statute is not penal in the conflict-of-laws sense because it was enacted to protect private creditors, not to vindicate the public interest of the state; therefore, Maryland must enforce the resulting judgment under full faith and credit.
Rule / Doctrine
A law is “penal” in the conflict-of-laws sense (and thus unenforceable in sister states) only if it is intended primarily to punish a public wrong for the benefit of the state or community, not when it creates a private right of action for the benefit of individuals injured by the wrong.
Significance
Huntington v. Attrill established the key distinction between penal statutes — which sister states need not enforce under full faith and credit — and civil remedy statutes protecting private rights, which must be enforced. This public/private distinction is foundational to the penal law exception in conflicts of laws.