## Facts

- Mills obtained a money judgment against Duryee in the Supreme Court of New York.
- Mills later filed an action of debt on that New York judgment in the Circuit Court for the District of Columbia.
- Duryee pleaded **nil debet** (general denial of owing the debt).
- Mills filed a general demurrer to the plea, arguing **nil debet** was improper in an action on a sister-state judgment.
- The circuit court sustained the demurrer and held the plea insufficient.
- Duryee sought Supreme Court review by writ of error.

## Issues

1. In an action of debt on a judgment rendered in another state, may the defendant plead **nil debet**, or is the proper plea limited to **nul tiel record** under the Full Faith and Credit Clause and the federal full faith and credit statute?
2. What effect must a properly authenticated sister-state judgment receive in a different jurisdiction’s court?

## Decision

- The Court affirmed the circuit court’s judgment.
- **Nil debet** is not a valid plea to an action founded on a judgment of another state.
- A properly authenticated sister-state judgment must be treated as a **record judgment** between the parties; the proper plea is **nul tiel record**.
- The judgment may be proved by the authentication method prescribed by federal statute, and such proof is record evidence equivalent in quality to inspection of the original record.

## Legal Principles

- Under Article IV, § 1 and the federal statute implementing full faith and credit, authenticated records of judicial proceedings must receive in other courts the same **faith and credit** they have in the courts of the rendering state.
- A sister-state judgment, once properly authenticated, is **conclusive between the parties** as a judgment record; the merits may not be retried through a general denial of indebtedness.
- In an action on a sister-state judgment, defenses are confined to record-based challenges, chiefly **nul tiel record** (denying the existence or validity of the judgment as a record), rather than **nil debet**.
- An authenticated copy, proved in the statutory manner, suffices as **record evidence** without requiring production of the original judgment record.
- The full faith and credit regime applies in federal and territorial fora, including the District of Columbia, by congressional enactment.

## Conclusion

The Court held that a properly authenticated judgment from another state must be treated as conclusive record evidence in the forum court, making **nil debet** an improper plea and limiting the defendant to **nul tiel record** and similar record-focused defenses.


Mills v. Duryee, 11 U.S. (7 Cranch) 481 (1813)