Mr. Justice Culver
delivered the opinion of the Court.
The State of California, petitioner, sued respondent, Dale W. Copus, now domiciled in Texas, for money expended by the State in the care, support and maintenance of. his mother, an incompetent inmate of a state institution. A judgment for the full .amount sued for was reversed and rendered by the Court of Civil Appeals. 301 S.W. 2d 217. We concur in the holding of the Court of Civil Appeals that no recovery can be had for support furnished after respondent removed to and became domiciled [198]*198in this state. But we disagree with the conclusion that the Texas two-year statute of limitation would apply to that portion of the claim arising prior to the removal of the respondent and that the maintenance of this action would be contrary to our public policy.
Prior to the 16th day of July, 1951, Copus was a resident citizen of the State of California. On that date he changed his domicile and residence to the State of Texas where he has continued to reside. For a number of years prior to the son’s removal to Texas the mother had been continuously and was at the time of the filing of this suit a patient in one of the California state hospitals.
By California statute an adult son is legally obligated to reimburse the state for sums expended by the state in the care and maintenance of an indigent parent in a state institution. Additionally the statute provides (Section 345, Code of Civil Procedure) as follows: “The limitations prescribed in this chapter apply to actions brought in the name of the State or county or for the benefit of the State or county, in the same manner as to actions by private parties, except that actions for the recovery of money due on account of the support of patients at State or county hospitals may be commenced at any time within four years after the accrual of the same.” Pursuant to the provisions of the Welfare and Institution’s Code the Director of Mental Hygiene of California fixed the rate for the care and support of this incompetent mother at $40.00 per month as of the 1st day of July, 1944. This rate was continued until the 1st day of August, 1951, when the Director increased the rate to $90.00 per month. That irate was continued up to the time of the filing of this suit.- The State of California sued respondent in the Texas court for the support of his mother at the rates prescribed for a period of four years prior to the bringing of this suit.
Three questions are presented: (1) Does the claim asserted by the State of California against Copus constitute a continuing obligation enforceable by the Texas courts for the mother’s support and maintenance that accrued after Copus has removed to and become domiciled in Texas? (2) Does the Texas two-year statute of limitation apply to this cause of action rather than the law of California? (3) Is the enforcement of this claim contrary to the public policy of the State of Texas?
No clear cut answer to these questions can be found by a [199]*199search of the Texas authorities, at least in so far as the first two are concerned, but a review of the decisions in this and other jurisdictions impels the conclusion that all three should be resolved in the negative.
The general rule rather universally recognized is that the statutes of a state ex proprio vigore have no extraterritorial effect. It must be concluded, therefore, that the California statute could not create a legal obligation upon a citizen of Texas who was not a citizen of California when the obligation arose, that is, at the time the mother became institutionalized in California or at any time thereafter. We are aware of no rule of law that would make the obligation a continuing one after removal from California even though it attached to him while a resident of that state. Citizens of a state equally share the burdens and privileges of citizenship regardless of when or how that status is attained. To say that the support statute compelled liability for that period of time after the respondent moved to Texas would seem to deny to him equality with other citizens of the state.
Petitioner contends that the obligation statutorily imposed is quasi or constructively contractual. On that premise it invokes the universal rule that the validity and interpretation of a contract are to be determined according to the law of the state where the contract is made and if valid there it is likewise valid elsewhere. To support this premise petitioner relies on the decision in State v. Stone, 271 S.W. 2d 741, Texas Civ. App., holding a similar Texas support obligation to be quasi contractual and thus a legal charge against the estate of the deceased obligor. But the claim in the Stone case matured during the lifetime of the obligor, the only question being whether the debt could be collected after his death from the estate. The court did not hold that the obligation survived the father’s death to the extent of making the estate liable for any care and maintenance furnished to the son after the father’s death. We think that the debt here is not of such a contractual nature as to impose legal liability on the respondent after he ceased to be a citizen of California and became domiciled in Texas.
This cause of action in so far as it concerns the accruals after respondent’s removal to Texas cannot be said to have arisen while respondent was under the legislative jurisdiction of California. Restatement Conflict of Laws, Sec. 457, puts it this way:
[200]*200“A state has legislative jurisdiction to impose upon one person a duty to support another person if
(a) the person to be supported is domiciled within the state and the person to support is subject to the jurisdiction of the state, or
(b) the person to support is domiciled within the state although the person to be supported is not subject to the jurisdiction of the state, or
(c) both parties are subject to the jurisdiction of the state, though neither is domiciled there.”
In Berkley v. Berkley, Mo., 246 S.W. 2d 804, 34 A.L.R. 2d 1456, the wife domiciled in California sued her husband, domiciled in Missouri, to recover a sum expended for the support of their minor child who was in the care and custody of the mother. The parties, prior to their separation, had resided in and were citizens of California. The defendant sought to have the California law applied that would relieve him of this obligation. The court to the contrary, held that the law of Missouri would control in this action.
Yarborough v. Yarborough, 290 U.S. 202, 54 Sup. Ct. 181, 78 L. Ed. 269, cited and relied upon in Berkley v. Berkley, supra, in passing upon a somewhat similar conflict decided:
“That the character and extent of the father’s obligation, and the status of the minor, are determined ordinarily, not by the place of the minor’s residence, but by the law of the father’s domicile.”
The law thus announced would control in the situation we have here. The State of Texas does not expressly and unqualifiedly impose upon a son a duty to reimburse the State for moneys expended and charged by the State for the support of an indigent parent in state hospitals. Vernon’s Civil Statutes, Art. 3196a, Section 2.
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Mr. Justice Culver
delivered the opinion of the Court.
The State of California, petitioner, sued respondent, Dale W. Copus, now domiciled in Texas, for money expended by the State in the care, support and maintenance of. his mother, an incompetent inmate of a state institution. A judgment for the full .amount sued for was reversed and rendered by the Court of Civil Appeals. 301 S.W. 2d 217. We concur in the holding of the Court of Civil Appeals that no recovery can be had for support furnished after respondent removed to and became domiciled [198]*198in this state. But we disagree with the conclusion that the Texas two-year statute of limitation would apply to that portion of the claim arising prior to the removal of the respondent and that the maintenance of this action would be contrary to our public policy.
Prior to the 16th day of July, 1951, Copus was a resident citizen of the State of California. On that date he changed his domicile and residence to the State of Texas where he has continued to reside. For a number of years prior to the son’s removal to Texas the mother had been continuously and was at the time of the filing of this suit a patient in one of the California state hospitals.
By California statute an adult son is legally obligated to reimburse the state for sums expended by the state in the care and maintenance of an indigent parent in a state institution. Additionally the statute provides (Section 345, Code of Civil Procedure) as follows: “The limitations prescribed in this chapter apply to actions brought in the name of the State or county or for the benefit of the State or county, in the same manner as to actions by private parties, except that actions for the recovery of money due on account of the support of patients at State or county hospitals may be commenced at any time within four years after the accrual of the same.” Pursuant to the provisions of the Welfare and Institution’s Code the Director of Mental Hygiene of California fixed the rate for the care and support of this incompetent mother at $40.00 per month as of the 1st day of July, 1944. This rate was continued until the 1st day of August, 1951, when the Director increased the rate to $90.00 per month. That irate was continued up to the time of the filing of this suit.- The State of California sued respondent in the Texas court for the support of his mother at the rates prescribed for a period of four years prior to the bringing of this suit.
Three questions are presented: (1) Does the claim asserted by the State of California against Copus constitute a continuing obligation enforceable by the Texas courts for the mother’s support and maintenance that accrued after Copus has removed to and become domiciled in Texas? (2) Does the Texas two-year statute of limitation apply to this cause of action rather than the law of California? (3) Is the enforcement of this claim contrary to the public policy of the State of Texas?
No clear cut answer to these questions can be found by a [199]*199search of the Texas authorities, at least in so far as the first two are concerned, but a review of the decisions in this and other jurisdictions impels the conclusion that all three should be resolved in the negative.
The general rule rather universally recognized is that the statutes of a state ex proprio vigore have no extraterritorial effect. It must be concluded, therefore, that the California statute could not create a legal obligation upon a citizen of Texas who was not a citizen of California when the obligation arose, that is, at the time the mother became institutionalized in California or at any time thereafter. We are aware of no rule of law that would make the obligation a continuing one after removal from California even though it attached to him while a resident of that state. Citizens of a state equally share the burdens and privileges of citizenship regardless of when or how that status is attained. To say that the support statute compelled liability for that period of time after the respondent moved to Texas would seem to deny to him equality with other citizens of the state.
Petitioner contends that the obligation statutorily imposed is quasi or constructively contractual. On that premise it invokes the universal rule that the validity and interpretation of a contract are to be determined according to the law of the state where the contract is made and if valid there it is likewise valid elsewhere. To support this premise petitioner relies on the decision in State v. Stone, 271 S.W. 2d 741, Texas Civ. App., holding a similar Texas support obligation to be quasi contractual and thus a legal charge against the estate of the deceased obligor. But the claim in the Stone case matured during the lifetime of the obligor, the only question being whether the debt could be collected after his death from the estate. The court did not hold that the obligation survived the father’s death to the extent of making the estate liable for any care and maintenance furnished to the son after the father’s death. We think that the debt here is not of such a contractual nature as to impose legal liability on the respondent after he ceased to be a citizen of California and became domiciled in Texas.
This cause of action in so far as it concerns the accruals after respondent’s removal to Texas cannot be said to have arisen while respondent was under the legislative jurisdiction of California. Restatement Conflict of Laws, Sec. 457, puts it this way:
[200]*200“A state has legislative jurisdiction to impose upon one person a duty to support another person if
(a) the person to be supported is domiciled within the state and the person to support is subject to the jurisdiction of the state, or
(b) the person to support is domiciled within the state although the person to be supported is not subject to the jurisdiction of the state, or
(c) both parties are subject to the jurisdiction of the state, though neither is domiciled there.”
In Berkley v. Berkley, Mo., 246 S.W. 2d 804, 34 A.L.R. 2d 1456, the wife domiciled in California sued her husband, domiciled in Missouri, to recover a sum expended for the support of their minor child who was in the care and custody of the mother. The parties, prior to their separation, had resided in and were citizens of California. The defendant sought to have the California law applied that would relieve him of this obligation. The court to the contrary, held that the law of Missouri would control in this action.
Yarborough v. Yarborough, 290 U.S. 202, 54 Sup. Ct. 181, 78 L. Ed. 269, cited and relied upon in Berkley v. Berkley, supra, in passing upon a somewhat similar conflict decided:
“That the character and extent of the father’s obligation, and the status of the minor, are determined ordinarily, not by the place of the minor’s residence, but by the law of the father’s domicile.”
The law thus announced would control in the situation we have here. The State of Texas does not expressly and unqualifiedly impose upon a son a duty to reimburse the State for moneys expended and charged by the State for the support of an indigent parent in state hospitals. Vernon’s Civil Statutes, Art. 3196a, Section 2. We hold there can be no recovery by the State of California against respondent for support rendered to his parent after respondent removed from the State of California and became domiciled in this State.
Petitioner relies partly upon our uniform Reciprocal Enforcement Act, Article 2328b, and particularly upon Section 7 thereof reading:
[201]*201“Duties of support enforceable under this law are those imposed or imposable under the laws of any state where the alleged obligor was present during the period for which support is sought or where the obligee was present when the failure to support commenced, at the election of the obligee, * *
But whether entitled to or not, the petitioner did not bring its suit under the provisions of this act nor comply therewith. We hold, therefore, that respondent is not liable for any sums accrued after his removal to this state.
As to the second question, namely, the applicability vel non of the Texas two-year statute of limitation, the general rule is that questions of substantive law are controlled by the laws of the state where the cause of action arose, but that matters of remedy and of procedure are governed by the laws of the state where the action is sought to be maintained. Home Ins. Co. v. Dick et al., Texas Com. App., 15 S.W. 2d 1028 reversed on other grounds 281 S.W. 397, 74 L. Ed. 926. To this rule there are exceptions.
The weight of authority favors the rule or exception to the foregoing general rule that where the statute creates a right and also incorporates a limitation upon the time within which the suit is to be brought, the limitation qualifies the right so that it becomes a part of the substantive law rather than procedural, and that unless suit is brought within the time allowed by statute no right of action can be maintained even though the law of the forum provides for a longer period of limitation. Stumberg Conflict of Laws, 2d. Ed. p. 150.
Some courts have gone further in holding that in such a situation the lex loci would prevail even though the time had elapsed under the limitation staute of the forum. This exception, as stated in 53 C.J.S., Limitation of Actions; Sec. 30, is as follows:
“Where by statute a right of action is given which did not exist by the common law, and the statute giving the right fixes the time within which the right may be enforced, the time so fixed becomes a limitation or condition on such right, and will control, no matter in what forum the action is brought, and such rule does not make the general provisions of the statute of limitations existing in the jurisdiction where the liability was created operate extraterritorially. * * • • •
[202]*202See also 15 C.J.S., Conflict of Laws, Sec. 22e.
Although there exists quite a cleavage among the authorities as to the validity of this exception,1 we prefer to follow those decisions that would treat the limitation in the California statute as substantive and not procedural. In Theroux v. Northern P. R. Co., 27 U.S. App. 508, 64 Fed. 84, the Court reasons as follows:
“Where a statute confers a new right, which by the terms of the act is enforceable by suit only within a given period, the period allowed for its enforcement is a constituent part of the liability intended to be created, and of the right intended to be conferred. The period prescribed for bringing suit in such cases is not like an ordinary statute of limitations, which merely affects the remedy. It follows, of course, that if the courts of another state refuse to permit the cause of action to be sued upon during a part of the period limited by the foreign law, to that extent they refuse to give effect to the foreign law, and by so doing impair the right intended to be created.”
Other cases supporting this theory are: Norman v. Baldwin, 152 Va. 800, 148 S.E. 831; Brunswick Terminal Co. v. National Bank, 99 Fed. 635, 48 L.R.A. 625; Negaubauer v. Great Northern Ry. Co., 92 Minn. 184, 99 N.W. 620; Nick Maki v. George R. Cooke Co., 124 Fed. 2d 663, 146 A.L.R. 1352 and Wilson v. Massengill, 124 Fed. 2d 666. The latter two cases expressly approve the doctrine advanced in Theroux v. Northern P. R. Co., supra. Strictly speaking, we think these two so-called exceptions to the general rule, that the law of the forum controls as to procedural matters, are not exceptions at all because the limitation on the statutory right is regarded as substantive and not one of remedy.
The contrary view, namely, that the limitation statute of the forum will control is expressed in Tieffenbrun v. Flannery, 198 N.C. 397, 151 S.E. 857, 68 A.L.R. 210, and Rosenzweig v. Heller, 302 Pa. 279, 153 A. 346, and others.
Again the United States Supreme Court in Engel v. Davenport, 271 U.S. 33, 70 L. Ed. 813, 46 Sup. Ct. 410, 413, in reversing the California decision, 194 Cal. 344, 228 Pac. 710, held the limitation provision in the Federal statute to be controlling [203]*203since the right to maintain the suit at any time within two years was a substantive right, an essential part of the cause of action so created, and not merely remedial, the Supreme Court saying that: “As a provision affecting the substantive right created by Congress in the exercise of its paramount authority in reference to the maritime law, it must control in an action brought in a state court under the Merchant Marine Act, regardless of any statute of limitation of the state.” It may be argued that the Federal statute enacted by the Congress in a field over which it has paramount authority might rest on a different basis from that of state legislative action. On the other hand it is difficult to see how there is a difference in principle because the State Legislature is equally paramount within its own jurisdiction.
For yet another reason, it would seem proper here to apply the California statute with respect to the time limitation. Although we have a general statute of limitations of two years, Art. 5526, Vernon’s Ann. Civ. Stat., applicable to “actions for debt where the indebtedness is not evidenced by a contract in writing,” it would not apply to a demand of this nature brought by the State of Texas. It would seem proper, therefore, under the circumstances, to extend comity to the State of California and uphold the right of that state to commence this action within the four-year period as provided in the California statute.
It cannot be said that the maintenance of this suit in Texas and the rendition of a judgment in California’s favor for the amount accruing before the respondent became a citizen of Texas is against the public policy of this state.2 It is true that our Legislature has not seen fit to enact a statute to impose legal liability upon a son for the maintenance of a parent inmate in a state institution, although it does by statute obligate the husband or wife and the father or mother, if financially able, to bear the expense of maintaining a patient in a state hospital where the patient has not sufficient estate of his own. Art. 3196a, Sec. 2, Vernon’s Ann. Civ. Stat. Sec. 5 of that article permits the state to proceed to collect the amount from those so obligated in a civil action. And not only that, but our Probate Code, Sec. 423, requires that an incompetent person, having no estate of his own, shall be maintained by the husband or wife and by the father or mother and even by the children and grandchildren, if able to do so.
[204]*204Although our Legislature has not adopted the policy of requiring an adult son to support a parent or to reimburse the state, under the circumstances involved here, it is quite another thing to say that it is against the public policy of this state to enforce the California obligation, and particularly so when our state has statutes of similar import and character. Strawn Mercantile Co. v. First National Bank of Strawn, (Texas Civ. App.), 279 S.W. 473; Texas & N. O. Ry. Co. v. Miller, 60 Texas Civ. App. 627, 128 S.W. 1165.
In this respect we think the rule is correctly announced in Herrick v. Minneapolis & St. L. Ry. Co., 31 Minn. 11, 16 N.W. 413: “To justify a court in refusing to enforce a right of action which accrued under the law of another state, because against the policy of our laws, it must appear that it is against good morals or natural justice, or that for some other such reason the enforcement of it would be prejudicial to the general interests of our own citizens.” This rule has been approved by the United States Court of Appeals for the Fifth Circuit. Evey v. Mexican Central Railway Co., 81 Fed. 304, 38 L.R.A. 387; Burt v. Isthmus Development Co., 218 Fed. 2d 353.
This California statutory requirement of support does not run counter to good morals or natural justice or appear prejudicial in any way to the general interest of the citizens of Texas.
We, therefore, hold that the petitioner is entitled to judgment for the sum of money charged by the State of California for the support of his mother while the respondent was a citizen of that state that accrued within four years of the commencement of this suit and will be denied recovery for any sums that accrued after respondent’s removal to this state.
The judgments of both the trial court and the Court of Civil Appeals are reversed and the cause remanded to the trial court for the entry of a decree in accordance with the foregoing views.
Opinion delivered January 15, 1958.