In the case of Davis v. Wakelee, the U.S. Supreme Court was asked to determine whether a judgment made in one state could be enforced in another if it had been obtained by default and without personal service on the defendant. The plaintiff, Davis, sued Wakelee for debt recovery in California but served him with notice while he was temporarily residing in Nevada. When Wakelee did not respond to this notice, a default judgement was issued against him which Davis sought to enforce back in California where both parties were domiciled. The court ruled that even though full faith and credit must generally be given to public acts, records and judicial proceedings of every other state under Article IV Section 1 of the Constitution (the Full Faith and Credit Clause), there are exceptions when due process is violated as per Fourteenth Amendment rights. In this case since no personal service had been effected upon Wakelee within California's jurisdiction before obtaining judgement by default - his right to due process had indeed been violated thus making enforcement invalid.

In the dissenting opinion for Davis v. Wakelee, Justice Brewer argued that a judgment should not be set aside simply because of an error in the proceedings if it does not affect the substantial rights of parties involved. He believed that there was no reason to believe any harm had been done to either party due to this technical mistake and therefore saw no need for a new trial. According to him, setting aside judgments on such minor errors would only serve as encouragement for lawyers to focus more on finding procedural mistakes than on presenting their case effectively and honestly. This could potentially lead courts into becoming arenas where legal acumen is tested rather than places where justice is sought and served.