Union National Bank v. Lamb

337 U.S. 38 (1949)

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Nature of the Case

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Facts

Missouri limits the life of a judgment to ten years after its original rendition or ten years after its revival. Missouri also provides that no judgment can be revived after ten years from its rendition. These provisions are applicable to all judgments whether rendered by a Missouri court or by any other court. P has a Colorado judgment against D. It was obtained in 1927 and revived in Colorado in 1945 on personal service upon D in Missouri. P then brought suit in Missouri on the revived Colorado judgment. P argued that the Full Faith and Credit obligated the Missouri court to use Colorado’s rule for reviving judgments. The court agreed with D who argued that Missouri law applied and dismissed the case. The Supreme Court of Missouri refused to enforce it because, under Missouri law, the original judgment could not have been revived in 1945. Missouri held that lex fori governs the limitations of actions and that the Full Faith and Credit Clause of the Constitution, Art. IV, § 1, did not require Missouri to recognize Colorado's more lenient policy as respects revival of judgments.