Witnesses
Other State - Injunction - Full Faith And Credit
Even though a Michigan court entered an injunction in settlement of an employee's wrongful discharge suit that prohibited the employee from testifying against the employer in products liability cases, a Missouri federal court could order the employee to testify in a products liability case brought by plaintiffs who were not parties to the Michigan suit and the order did not violate the full faith and credit clause of the United States Constitution.
Judgment of the U.S. Court of Appeals, Eighth Circuit, is reversed and the case is remanded.
Injunction
"Most essentially, Michigan lacks authority to control courts elsewhere by precluding them, in actions brought by strangers to the Michigan litigation, from determining for themselves what witnesses are competent to testify and what evidence is relevant and admissible in their search for the truth....
"[A] Michigan court cannot, by entering the injunction to which [the employee] and [the employer] stipulated, dictate to a court in another jurisdiction that evidence relevant in the [plaintiffs'] case -- a controversy to which Michigan is foreign -- shall be inadmissible....
"The Michigan judgment is not entitled to full faith and credit...because it impermissibly interferes with Missouri's control of litigation brought by parties who were not before the Michigan court....
"In sum, Michigan has no authority to shield a witness from another jurisdiction's subpoena power in a case involving persons and causes outside Michigan's governance. Recognition, under full faith and credit, is owed to dispositions Michigan has authority to order. But a Michigan decree cannot command obedience elsewhere on a matter the Michigan court lacks authority to resolve.''
Reversed and remanded.
Baker, et al. v. General Motors Corporation (MLW No. 21738) (29 pages)(Ginsburg, J.)(separate concurring opinion by Scalia, J.)(separate concurring opinion by Kennedy, J., joined by O'Connor and Thomas, JJ.) Appealed from the United States Court of Appeals, Eighth Circuit, Beam, J. (Robert L. Langdon and J. Kent Emison, Lexington, Mo., for appellants) (Richard Bowman, David Kelly and Steven L. Reitenour, Minneapolis, Minn., for respondent).
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