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M'Kim v. Voorhies was a case heard by the United States Supreme Court in 1812. The dispute arose when John M’Kim, an attorney from Pennsylvania, sued William Voorhies for failing to pay him $2,000 that had been awarded as part of a judgment against another party. The court found that although the original award had been made in New Jersey and not Pennsylvania, it still applied under the Full Faith and Credit Clause of Article IV of the Constitution because both states were part of the same union at that time. As such, M’Kim was entitled to receive payment from Voorhies since he held legal title to those funds on behalf of his client who won the original lawsuit in New Jersey. Ultimately, this decision established precedent for how judgments between different states should be handled within our federal system today.
In M'Kim v. Voorhies, Chief Justice Marshall delivered the dissenting opinion of the Supreme Court. He argued that a state court had no authority to issue an injunction against a federal officer in order to prevent him from executing his duty under federal law. The case involved a dispute between two creditors over who should receive payment first from funds held by the Collector of Customs for New York City. The state court issued an injunction ordering the collector not to pay either creditor until further orders were given by it or another competent tribunal, and this was challenged as being beyond its jurisdiction since it interfered with federal officers performing their duties under national laws passed pursuant to constitutional powers granted exclusively to Congress. Marshall maintained that such interference could only be done through acts of Congress and not through any other means, including those employed by state courts which lacked authority over matters concerning foreign commerce or revenue collection delegated solely to Congress in Article I Section 8 of the Constitution.