Does the Full Faith and Credit Clause compel a state to enforce another state's injunction restricting witness testimony in courts outside that state's jurisdiction?

Ronald Elwell, a former engineering analyst at General Motors (GM), was subject to an injunction issued by a Michigan court. This injunction prohibited Elwell from testifying against GM without the company's consent, following a lawsuit between Elwell and GM. In a separate case, Kenneth and Steven Baker initiated a wrongful death lawsuit against GM in Missouri. The lawsuit was related to the death of their mother, Beverly Garner, in a car accident involving a GM vehicle. The Bakers sought to have Elwell testify as a witness in their case against GM.

GM objected to Elwell's potential testimony, citing the Michigan injunction. Notably, the Bakers were not parties to the original Michigan case that resulted in the injunction against Elwell. This situation created a legal conflict between the Michigan injunction prohibiting Elwell's testimony and the Bakers' desire to have him testify in their Missouri lawsuit against GM.

The Bakers initiated a wrongful death lawsuit against General Motors (GM) in Missouri state court. GM subsequently removed the case to federal court. In the federal district court proceedings, GM objected to the testimony of Elwell, but the court allowed Elwell to testify. The jury returned a verdict in favor of the Bakers. GM appealed the decision to the Eighth Circuit Court of Appeals. The appellate court reversed the lower court's ruling, determining that Elwell's testimony should have been excluded due to an existing injunction from Michigan. Following this reversal, the case progressed to the United States Supreme Court for further review.

(Ginsburg, J.)

No. The Full Faith and Credit Clause does not compel a state to enforce another state's injunction restricting witness testimony in courts outside that state's jurisdiction. While states must recognize each other's judgments, this obligation does not extend to controlling court procedures or binding parties in other jurisdictions. The Full Faith and Credit Clause has limits in its application to judicial proceedings and cannot be used to dictate evidentiary rules or witness competency in foreign tribunals. A state lacks the authority to preclude courts in other states from determining the admissibility of testimony, especially when the parties in the foreign litigation were not involved in the original case. This principle preserves the autonomy of state courts to manage their own proceedings and make independent evidentiary determinations. The restriction on enforcing out-of-state injunctions against witness testimony stems from fundamental concepts of state sovereignty and the limited reach of one state's judicial power beyond its borders. Enforcing such injunctions would improperly allow one state to project its laws and judicial decisions into the territory of another sovereign state, undermining the independence of each state's judicial system. Furthermore, it would create practical difficulties in litigation, potentially depriving courts of relevant testimony and interfering with their truth-seeking function. The decision upholds the principle that each state retains control over its own judicial processes, including decisions about witness competency and admissibility of evidence, regardless of injunctions issued by courts in other states.

Concurrence (Scalia, J.) Enforcement measures do not travel with sister-state judgments. This case can be decided on this simpler principle without the need for the majority's extended analysis. The full faith and credit clause does not require states to adopt the practices of other states regarding the time, manner, and mechanisms for enforcing judgments. This straightforward approach provides a clear rule for future cases involving cross-state enforcement of judgments.

Concurrence (Kennedy, J.) This case can be resolved by applying well-settled full faith and credit principles. The focus should be on the fact that Michigan law would not give preclusive effect to the injunction against parties not involved in the original litigation. This approach maintains consistency with established precedent and avoids unnecessary expansion of the Court's jurisprudence on interstate enforcement of judgments. The majority's analysis goes beyond what is necessary to decide this case and may create confusion in future applications of the full faith and credit clause.