Hazzard v. Nottingham

1 Tapp. Rep. 146
CourtJefferson County Court of Common Pleas
DecidedApril 15, 1817
StatusPublished

This text of 1 Tapp. Rep. 146 (Hazzard v. Nottingham) is published on Counsel Stack Legal Research, covering Jefferson County Court of Common Pleas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hazzard v. Nottingham, 1 Tapp. Rep. 146 (Ohio Super. Ct. 1817).

Opinion

President.

It is urged in support of the demurrer to this declaration, that an action of debt will not lie on a judgment obtained in another state or country; that the proper form of action is assumpsit; but that if debt will lay at all, it can only be debt on simple contract, in which the whole proceedings must be set forth, with an averment that the original cause of action was within the jurisdiction of the court. On the other side it is contended, that, by the constitution and law of the United States, a judgment rendered in one state, is to have the same effect in every other state, as it may by law have in the state where it is rendered; and that this form of action is not only the proper form, but that it is the only legal method in which suits may be brought on such judgments.

To support this declaration, it would seem unnecessary to enquire farther than whether debt be the proper form of action, and this the usual mode of declaring on foreign judgments. For if the judgments of the other states are to be considered as foreign : as evidence of simple contracts only, yet it does not follow that this form [147]*147of action is not the usual and proper form, or that it is necessary to set forth and aver more than is set forth and averred in this declaration. But as the subject has undergone an elaborate discussion, and the opinion of the court is desired on the question, how far the judgment of another state is to conclude a party sued on it here, I will proceed to give that opinion, although it is not directly necessary in deciding this demurrer.

If there is any intricacy and difficulty in this subject, it appears to be rather owing to the contradictory opinions which have been holden in the different states by men of eminent talents and learning, than to any obscurity in the constitution and law. The constitution provides, art. 4th, sec. 1st, that “full faith and credit shall be given in each “ state to the public acts, records, and judicial proceedings, of every “ other state. And congress may, by general laws, prescribe the “ manner in which, such acts, records, and proceedings, shall be proved, “and the effect thereof.”-¿The act of congress “to prescribe the mode in which the public acts, records, and judicial proceedings, in each state, shall be authenticated, so as to take effect in every other state,” is “ that the acts of the legislatures of the several states shall be “ authenticated by having the seal of their respective states affixed “thereto; that the records and judicial proceedings of the courts of “ any state, shall be proved or admitted in any other court within the “ United States, by the attestation of the clerk, and the seal of the “ court annexed, “ if there be a seal, together with a certificate of the “ judge, .chief justice, or presiding magistrate, as the case may be, that “ the said attestation is in due form; and the said records and judicial “proceedings, authenticated as aforesaid, shall have such faith and “ credit given to them in every court within the United States, as they “ have by law or usage in the courts of the state from whence the said “ records are, or shall be, taken.”

The first case in which a construction was given to this law, is that of Armstrong vs. Carson’s executors, 2d Dallas 302, debt. In the circuit court of Pennsylvania, on a judgment obtained in the supreme court of the state of New Jersey, it was holden that nil debet could not be received as a plea to such action, “ because it would be bad in the courts of New Jersey,” and that “whatever doubts there might be on the words of the constitution, the act of congress effectually removes them, declaring, in direct terms, that the record shall have the same effect in this court, as in the court from which it was taken.” In the case of Green vs. Sarmiento, appendix to Brown’s Reports 32, in the same court, Judge Washington considers a judgment of the mayor’s [148]*148court in New York, as conclusive evidence of debt in Pennsylvania; and he construes the terms faith and credit act 0f corigress, as synonymous ivith force and effect. j pave n0£ seen any 0yier eage which the question has been agitated in the Pennsylvania courts, except the case of Wright vs. Tower, reported in the appendix to Brown’s Reports, 1st page, in which it was ruled that the judgment of another state is to be considered as a foreign judgment, and prima facie evidence only of debt

In the state of New York, by an uniform series of decisions, it has been settled, that a judgment of another state is not conclusive, but only prima facie evidence of debt to be considered as a foreign judgment, 1st Caines, 460; 8th Johns, 173. A similar decision was made by the supreme court of Massachusetts in the case of Bartlett vs. Knight, 1st Mass. Rep. 401. The same court afterwards, in the case of Noble vs. Gold, 1st Mass. Rep. 410, note, decided that, “by the constitution and law of the United States, the judgments of the courts of record in the several states were placed, in all respects, upon the same footing with their own domestic judgments.” The same question has been since raised in that court, and a decision made, which takes a middle course between the former ones, 9th Mass. Rep. 462, by the opinion of two judges against one (the other two absent) it was adjudged that “the judgments rendered in the courts of the other states were not to be considered as foreign judgments;” neither were they to be considered as domestic judgments rendered in our own courts of record, “ that they might be declared on as evidence of debts or promises, and on the general issue, the jurisdiction of the courts rendering them is put in issue; but not the merits of the judgments.” The judge who dissented, and the two who were absent m this case, composed the court when the case of Bai tlett vs. Knight was decided, so that we may consider the law on this subject as yet unsettled in Massachusetts. The case of Mills vs. Duryea, 7th Cranch, 481, is the only case I have any knowledge of, in which this question has been made in the Supreme Court of the United States; that was debt upon a judgment of the supreme court of the state of New York, to which the defendant pleaded nil debet: upon general demurrer, the plea was adjudged bad by a majority of the court.

I have not found (not having had much time to examine) that the question has been directly adjudicated upon in the other states. In this state, the supreme court, in the case of Magner vs. [149]*149Case, Trumbull County 1805, were of opinion that the record of a judgment by default, obtained in Washington County, Pennsylvania, was conclusive between the parties. Nil debet had been pleaded in that case, and issue joined; the court considered it as an improper plea, and intimated that if it had been demurred to, the demurrer would have been sustained. In the year 1809, the supreme court, sitting in the same, county, in the case of Tappan vs. Austin, (which was debt on a judgment rendered by the supreme court of Massachusetts) decided that the record was but prima facie evidence of debt, and that the defendant was at liberty, on the issue joined, on the plea of nil debet to go into the consideration of the judgment, although it appeared by the record that an appearance and defence had been made, and a full investigation of the merits had, in the original suit. I have not known of any other decision in this state.

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1 Tapp. Rep. 146, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hazzard-v-nottingham-ohctcompljeffer-1817.