## Facts

- The Order of United Commercial Travelers of America was an Ohio-incorporated fraternal benefit society operating in multiple states under a detailed Ohio statutory scheme.
- Ford Shane, a South Dakota citizen, became a member in 1920, remained domiciled in South Dakota, and died in 1931.
- The society’s constitution provided death benefits but required any action on a disallowed claim to be brought within six months after disallowance by the society’s Supreme Executive Committee.
- Wolfe, the claimant/beneficiary, sued in South Dakota state court after the six-month period had expired but within South Dakota’s general six-year limitations period for contract actions.
- South Dakota had a statute declaring void contractual provisions that limit the time to enforce rights through usual legal proceedings.
- Ohio law treated the society’s six-month limitations provision as valid and enforceable.

## Issues

1. Whether the Full Faith and Credit Clause required South Dakota courts to enforce an Ohio-authorized six-month limitation in a fraternal benefit society’s constitution, despite South Dakota statutes and limitations rules to the contrary.
2. Whether a death-benefit claim based on membership rights in a multistate fraternal benefit society is governed, for limitations purposes, by the law of the incorporating state.

## Decision

- The Supreme Court reversed the judgment for Wolfe.
- South Dakota was constitutionally required to give full faith and credit to Ohio’s public acts governing the society’s incorporation and internal membership obligations.
- The claimant was bound by the society’s six-month limitation; the action filed after that period was time-barred.

## Legal Principles

- The Full Faith and Credit Clause can require a forum state to apply the incorporating state’s law to membership obligations of an incorporated fraternal benefit society.
- A claim for benefits grounded in fraternal-society membership rights under a constitution subject to amendment through representative governance differs from an ordinary insurance contract claim.
- A forum state’s statute voiding contractual time-to-sue limitations cannot be applied to defeat an incorporating state’s authorized rules governing a fraternal benefit society’s internal membership obligations when full faith and credit is owed.

## Conclusion

Because the asserted right arose from membership in an Ohio-chartered fraternal benefit society and Ohio law validated the society’s constitutional six-month suit limitation, South Dakota had to enforce that limitation under the Full Faith and Credit Clause, rendering the late-filed action barred.


Order of United Commercial Travelers of Am. v. Wolfe, 331 U.S. 586 (1947)