Anderson Petroleum Services, Inc. v. Chuska Energy & Petroleum Co.

4 Navajo Rptr. 187
CourtUnited States District Court
DecidedOctober 26, 1983
DocketNo. WR-CV-72-83
StatusPublished
Cited by1 cases

This text of 4 Navajo Rptr. 187 (Anderson Petroleum Services, Inc. v. Chuska Energy & Petroleum Co.) is published on Counsel Stack Legal Research, covering United States District Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson Petroleum Services, Inc. v. Chuska Energy & Petroleum Co., 4 Navajo Rptr. 187 (usdistct 1983).

Opinion

Honorable Tom Tso, Judge presiding.

STATEMENT OF THE CASE

This is a case where the plaintiff received in their favor a Journal Entry of Judgment from the District Court in and for Payne County, State of Oklahoma on February 4, 1983. Plaintiff is now asking this Court to declare the Oklahoma court order a valid judgment and to enforce the judgment through full faith and credit or comity. The Plaintiff is also asking, in addition to the total amount of the Oklahoma judgment, reasonable attorney fees and cost earned or incurred in the Payne County District Court action.

The Defendants argue that this Court should reject the Oklahoma court order and not declare it a valid judgment and that full faith and credit for the judgment should be denied.

The questions this court must deal with are:

(1) Whether this court should give full faith and credit to judgment of other states courts? (2) Can and should this court enforce the Oklahoma state order utilizing the doctrine of comity?

THE ISSUE OF FULL FAITH AND CREDIT

Assuming that a state had proper personal jurisdiction over the parties, the subject matter involved, and all due notices have been met and a judgment was properly issued. Under the circumstances, therefore, can this court give that judgment the same faith, credit, conclusive effect and obligatory force as it had by law or usage in the state from which it was granted? To answer this question we must first decide where this statutory clause regarding such authority derived from.

Full faith and credit is a clause of the Constitution of the United States at Article IV, Section 1, which requires that a foreign judgment be given such full faith and credit as it had by law or usage of the state of its origin.

Basically, this provision of the United States Constitution requires that one state shall give full faith and credit to the judgment of its sister state. The ultimate question presented now is, can the Navajo Courts give full faith and credit to the judgment of another state.

[188]*188The Navajo Court of Appeals dealt with this same issue in the case of, In the Matter of the Guardianship of Katherine Denise Chewiwi, 1 Navajo Reporter 120, (1977). In particular, the court in the Chewiwi case dealt with the issue of whether the concept of full faith and credit is applicable to the relationship between courts of different Indian Tribes.

In the Chewiwi case the Court in discussing the concept of full faith and credit concluded the Navajo Nation and the Isleta Pueblo stand beyond the bounds of this rule of law, since it presently exists and governs the constitutional relationship of the States of the United States, Id, at 124. The Court went on to say the Indian Nations and Tribes were not signatories to the U.S. Constitution and were not intended to be included with the scope of the mandate of Article V. Section 1. Nor does Title 28, U.S. Code, Section 1738, which was written to effectuate the mandate of Article 4, Section 1, provide a clear guidance to the relationships between Indian Courts. Id. at 125.

Fortunately, the courts of appeals in the Chewiwi case also discussed the case of Jim v. CIT, 533 P. 2nd, 751, decided by the Supreme Court of New Mexico and also the effects of 28 USC, Section 1738 on Indian Courts. Basically, that is the same argument raised by the Plaintiff in this instant case. In answering the presented issues, the court stated in their opinion a careful reading of the Jim v. CIT decision will show that the real issue presented by the facts of that case related to the conflicts of law doctrine. The New Mexico Supreme Court determined that, pursuant to New Mexico's uniform commercial code, parties to a contract may determine which law, given the applicability of more than one, shall govern. Id at 125.

Finally, the Court of Appeals concluded that 28 U.S.C. Section 1738, does not purport to govern the relationship betwee Indian courts. The constitutional provision upon which it is based did not envision Indian courts being in existence nor did the act itself. The status of the decision of Indan Courts is generally determined not in relations to "full faith and credit" but to the concept of the exclusive jurisdicton of each Indian court over certain matters, statutory federal law and U.S. Supreme Court decisions. Id at 126. On September 22, 1983, the district court for the District of New Mexico in Platero, et. al. v. Platero, Navajo Tribe, et. al., CIV No. 83-0952 stated that... "Indian Tribes are not" states,... territories or possessions" within the meaning of Section 1738A, therefore, the Navajo Courts are not required to give full faith and credit to the Mescalero Tribal Order." Brown v. Babbit Ford, Inc., 117 Ariz. 192, 571 P. 2d 689 (1976); Contra, Mackey v. Coxe, 59 U.S. (18 How.) 100 (1855); Raymond v. Raymond, 83 F. 721 (8th Cir. 1897); Jim v. CIT Financial Services Corp., 87 N.M. 362, 533 P. 2d 751 (1975); F. Cohen, Handbook of Federal Indian Law, 145, 172 (1942); Ragsdale, Problems in the Application of Full Faith and Credit for Indian Tribes, 7 N.M. L. Rev. 133 (1977)." Such question as presented to the federal court on the issue of full faith and credit therefore was left unanswered.

Therefore, this court cannot give full faith and credit to the Oklahoma court order based on the "full faith and credit" clause of the U.S. Constitution Article IV, Section 1.

[189]*189THE ISSUE OF COMITY

The court having discussed the issue of full faith and credit now comes to the second question which is whether or not this court can or should give enforcement to the Oklahoma court order based on the doctrine of comity?

Comity is a willingness to grant a privilege, not as a matter of right, but one of deference and good will.

In the Chewiwi decision the Navajo Court of Appeals ruled that when decisions of any state or Indian Courts is presented to the Courts of the Navajo Nation for enforcement the applicable disposition is one of comity.

Finally, the court stated that Navajo Courts will honor and enforce foreign judgments upon consideration of the rights of the foreign court to issue the judgment, of the propriety of the proceedings and of any relevant public policy of the Navajo Nation.

Essentially, the Court of Appeals gave a check list to the Navajo Courts to utilize in deciding whether it should enforce a foreign judgment. In the instant case the court will utilize the check list by first making some findings pursuant to the testimony and evidence adduced at the hearing on October 6, 1983, as follows:

1. Plaintiff Anderson Petroleum Services, Inc. is a corporation duly authorized under the laws of the State of Oklahoma with their principal offices at Stillwater, Oklahoma.

2. Defendant, Chuska Energy and Petroleum, Co. Inc., is a corporation duly authorized under the laws of the State of New Mexico, its registered office at Tohatchi, within the Navajo Nation and a suboffice in Albuquerque, New Mexico.

3. The parties entered into an agreement whereby they agreed that the Plaintiff would do an environmental impact study over one hundred and sixtyseven (167) acres of land on the Navajo Reservation and Defendant would pay Plaintiff One dollar and Fifty cents ($1.50) per acre.

4. The agreement was signed by the Plaintiff in Houston, Texas, on the 28th day of July, 1982.

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Bluebook (online)
4 Navajo Rptr. 187, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-petroleum-services-inc-v-chuska-energy-petroleum-co-usdistct-1983.