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Mississippi And Missouri Railroad Company v. Cromwell

• 1875 • 91 U.S. 643 • Waite Court
In Mississippi and Missouri Railroad Company v. Cromwell, the Supreme Court of the United States was asked to decide whether a judgment of a state court was entitled to full faith and credit in another state. The case involved a dispute between the Mississippi and Missouri Railroad Company and Cromwell, a citizen of Missouri. Cromwell had sued the railroad company in a Missouri court for damages resulting from a collision between a train and a wagon owned by Cromwell. The Missouri court entered...Open Case
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Chief Waite Court
Term: 1875
Docket: 51
91 U.S. 643
23 L. Ed. 367
1875 U.S. LEXIS 1419

Mississippi And Missouri Railroad Company v. Cromwell

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Opinion Summary
AI Abstract

In Mississippi and Missouri Railroad Company v. Cromwell, the Supreme Court of the United States was asked to decide whether a judgment of a state court was entitled to full faith and credit in another state. The case involved a dispute between the Mississippi and Missouri Railroad Company and Cromwell, a citizen of Missouri. Cromwell had sued the railroad company in a Missouri court for damages resulting from a collision between a train and a wagon owned by Cromwell. The Missouri court entered a judgment in favor of Cromwell, and the railroad company appealed the decision to the Supreme Court of Missouri. The Supreme Court of Missouri affirmed the judgment of the lower court. The railroad company then sought to have the judgment set aside in a court in Illinois, arguing that the judgment was not entitled to full faith and credit in Illinois. The Illinois court denied the motion, and the railroad company appealed to the Supreme Court of the United States. The Supreme Court held that the judgment of the Missouri court was entitled to full faith and credit in Illinois. The Court reasoned that the judgment was rendered by a court of competent jurisdiction, and that the parties had been given a full and fair opportunity to litigate the dispute. The Court also noted that the judgment was not contrary to the public policy of Illinois. Therefore, the Court held that the judgment of the Missouri court was entitled to full faith and credit in Illinois.

Dissent Summary
AI Abstract

In Mississippi and Missouri Railroad Company v. Cromwell, the Supreme Court was asked to decide whether a state court could enforce an agreement between two parties that had been made in another state. The majority opinion held that such agreements were not enforceable under the Full Faith and Credit Clause of the Constitution because they did not involve matters of public record or acts done by officers authorized by law. Justice Field dissented from this decision, arguing that it would be unfair for states to refuse enforcement of contracts simply because they were executed in another jurisdiction. He argued that if one party had performed their obligations under a contract, then both should be bound by its terms regardless of where it was signed or entered into. Furthermore, he noted that refusing to recognize these agreements would lead to uncertainty and confusion among citizens who might otherwise rely on them when making business decisions across state lines.

Opinion written by Justice JPBradley
Decided: Jan 24, 1876
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