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In Ohio and Mississippi Railroad Company vs. Wheeler, the Supreme Court was asked to decide whether a state court could enforce an injunction against a railroad company that had been issued by another state's court. The plaintiff in this case, Wheeler, had obtained an injunction from the Circuit Court of Illinois restraining the defendant railroad company from constructing its road across certain lands owned by him in Indiana. The defendant argued that such an injunction should not be enforced because it violated both federal law and public policy as well as being unconstitutional under Article IV of the Constitution which states that "Full Faith and Credit shall be given in each State to the public Acts, Records, and judicial Proceedings of every other State." In its decision, however, the Supreme Court held that while full faith and credit must be given to judgments rendered by courts of one state within another state’s jurisdiction; nevertheless there are limits on how far those judgments can extend beyond their own borders. Thus they concluded that since no part of any act or proceeding took place outside Illinois' jurisdiction then no part could have effect outside it either; therefore they reversed judgment for Wheeler with costs awarded against him.
In Ohio and Mississippi Railroad Company vs. Wheeler, the Supreme Court was tasked with determining whether a railroad company could be held liable for damages caused by its negligence in failing to properly maintain its tracks. The majority opinion found that the railroad company was not liable because it had no control over how much care individuals took when crossing their tracks. Justice Nelson dissented from this decision, arguing that the railroad company should have been held responsible for any injuries or deaths resulting from their failure to keep their track in good condition. He argued that since they were operating a business on public land, they had an obligation to ensure safety of those using it and thus should be held accountable if something went wrong due to lack of maintenance or other negligence on their part.