## Facts

- Ronald Elwell worked for General Motors Corporation (GM) for decades, including as an engineering analyst who assisted GM in product-liability defense work concerning vehicle fires.
- After his relationship with GM deteriorated, Elwell gave deposition testimony in a Georgia products-liability case that was unfavorable to GM and inconsistent with prior testimony he had given as a GM witness.
- Elwell later sued GM in Michigan over employment-related claims; GM counterclaimed. The dispute settled, and a Michigan court entered a stipulated permanent injunction prohibiting Elwell, absent GM’s written consent, from testifying in litigation involving GM, with a carve-out preserving the Georgia court’s jurisdiction.
- A separate settlement term provided that GM would not pursue contempt or breach claims against Elwell for testimony compelled by subpoena or tribunal order.
- Kenneth Lee Baker and Steven Robert Baker brought a Missouri wrongful-death/products-liability action against GM, alleging a defective GM fuel pump caused a vehicle fire that killed their mother.
- The Bakers subpoenaed Elwell; GM invoked the Michigan injunction to block his testimony.
- The Missouri federal district court allowed Elwell’s deposition and trial testimony; a jury returned an $11.3 million verdict, including $4 million in punitive damages.
- The Eighth Circuit reversed, ruling that full faith and credit required enforcement of the Michigan injunction and exclusion of Elwell’s testimony, and ordered a new trial.

## Issues

1. Whether the Full Faith and Credit Clause and 28 U.S.C. § 1738 required a Missouri court to enforce a Michigan injunction that purported to bar a nonparty witness from testifying in separate litigation brought by different plaintiffs in another State.
2. Whether full faith and credit obligates sister States to apply another State’s injunction as an evidentiary bar controlling proceedings over which the issuing State lacked jurisdiction.

## Decision

- The Supreme Court unanimously reversed the Eighth Circuit.
- The Court held that Missouri was not constitutionally required to enforce the Michigan injunction to bar Elwell’s testimony in the Missouri action.
- The Court distinguished recognition of judgments’ preclusive effects from enforcement mechanisms, holding that enforcement measures remain subject to forum control.
- The Court concluded that Michigan’s injunction resolved rights only between GM and Elwell and could not dictate evidentiary rulings in litigation involving nonparties to the Michigan proceeding.

## Legal Principles

- Full faith and credit generally requires States to give sister-state judgments the same preclusive effect they would receive in the rendering State, but it does not compel adoption of another State’s enforcement devices.
- Enforcement mechanisms, including injunctions aimed at controlling conduct, do not automatically operate extraterritorially and remain governed by the forum State’s evenhanded procedural and evidentiary law.
- A State court may not, through an injunction, control proceedings in another State’s courts involving parties not subject to the issuing court’s jurisdiction and lacking notice and an opportunity to be heard.
- The Court rejected a broad, freestanding “public policy exception” to full faith and credit for judgments; the result turned on limits of jurisdiction and the recognition/enforcement distinction.

## Conclusion

Missouri could admit a nonparty witness’s relevant, nonprivileged testimony notwithstanding a Michigan injunction arising from a separate settlement between the witness and GM, because full faith and credit did not require Missouri to treat that injunction as an extraterritorial evidentiary bar in litigation involving different parties.


Baker v. Gen. Motors Corp., 522 U.S. 222 (1998)