Treinies v. Sunshine Mining Co.
Citation and Court
308 U.S. 66 (1939), Supreme Court of the United States
Facts
Conflicting claims to stock in Sunshine Mining Co. were litigated in both Idaho and Washington courts. The Idaho court determined it had jurisdiction and adjudicated the ownership dispute. The Washington court then asserted its own jurisdiction and reached a different result. The Supreme Court had to determine which court’s judgment was entitled to full faith and credit.
Issue
Whether the Full Faith and Credit Clause requires a state court to give preclusive effect to a prior sister-state judgment even if the first court’s jurisdictional determination was erroneous, provided jurisdiction was actually litigated in the first proceeding.
Holding
The Washington judgment must give full faith and credit to the Idaho judgment; once a court actually litigates and decides its own jurisdiction, that determination is entitled to full faith and credit even if erroneous, and may not be re-litigated in a second forum.
Rule / Doctrine
Full faith and credit extends even to erroneous jurisdictional determinations if the jurisdictional question was actually litigated and decided in the first proceeding. A party who appeared in the first forum and contested jurisdiction, and lost, cannot re-litigate jurisdiction in the second forum.
Significance
Treinies reinforces and extends Durfee v. Duke’s holding: the actual litigation of jurisdiction in the first forum bars collateral attack in a second forum, even when the first court’s jurisdictional ruling may have been wrong. This promotes finality and prevents re-litigation of jurisdictional questions in serial proceedings.