## Facts

- In 1840 in Mississippi, Christmas (a Mississippi resident) executed and delivered a promissory note payable in 1841.
- The payee endorsed the note to Russell, a Kentucky resident.
- Under Mississippi limitation law, a suit on the note would have been time-barred by 1847 if brought in Mississippi.
- In 1853, while visiting Kentucky, Christmas was sued in Kentucky state court on the note; he appeared and litigated defenses, including limitations.
- A Kentucky court entered judgment for the noteholder in 1857, and the Kentucky Court of Appeals affirmed in 1859.
- Russell filed an action of debt in federal court in Mississippi to enforce the Kentucky judgment using an authenticated judgment record.
- Christmas relied on a Mississippi statute (enacted 1857) providing that no action may be maintained in Mississippi on an out-of-state judgment against a Mississippi resident if the underlying claim would have been time-barred under Mississippi law when first sued upon.
- Christmas also pleaded that the Kentucky judgment was procured by fraud; the plea did not set out detailed facts of the alleged fraud.

## Issues

1. Whether Mississippi may, consistent with the Full Faith and Credit Clause and the federal full-faith-and-credit statute, bar an action on a sister-state judgment because the underlying claim would have been time-barred under Mississippi limitations law.
2. Whether a plea alleging that a sister-state judgment was procured by fraud is subject to a general demurrer for failure to plead the particulars of the fraud.

## Decision

- The Supreme Court affirmed the judgment enforcing the Kentucky judgment in Mississippi.
- The Court held the Mississippi statute unconstitutional and void to the extent it prevented enforcement of a valid sister-state judgment based on Mississippi limitation policy applied to the underlying claim.
- The Court stated that a fraud plea cannot be defeated by a general demurrer solely for lack of particularity; if attacked for that defect, it must be by special demurrer.
- Despite the error in sustaining a general demurrer to the fraud plea on specificity grounds, the Court found no basis to reverse on the record as presented.

## Legal Principles

- A final judgment rendered by a state court with jurisdiction and proper notice must be given in other states the same effect it has in the rendering state under the Full Faith and Credit Clause and Congress’s implementing statute.
- A state may not enact legislation that effectively nullifies or materially impairs enforcement of sister-state judgments by conditioning enforcement on the forum state’s limitation rules governing the original cause of action.
- Sister-state judgments are conclusive on the same subject matter, subject to limited collateral inquiry into jurisdiction and notice, and potentially fraud in procurement.
- A demurrer asserting that a fraud plea lacks specific allegations addresses a pleading defect of form and requires a special demurrer, not a general demurrer.

## Conclusion

The Court required Mississippi courts to enforce a Kentucky judgment as conclusive and rejected Mississippi’s attempt to bar enforcement through a statute linking judgment enforceability to local limitation defenses applicable to the original debt, while clarifying that lack of particularity in a fraud plea is a matter of form for special demurrer.


Christmas v. Russell, 72 U.S. 290 (1866)