## Facts

- Wiley George, an engineer employed by Tennessee Coal, Iron & Railroad Company, was injured at the company’s steel plant in Jefferson County, Alabama.
- While George was repairing brakes under a locomotive, a defective throttle allegedly caused steam to move the engine forward, seriously injuring him.
- George sued the employer in a Georgia state court by attachment, asserting liability under Alabama Code § 3910 (employer liability for injuries caused by defects in the employer’s ways, works, machinery, or plant).
- The employer pleaded in abatement that Alabama Code § 6115 required suits under § 3910 to be brought only in Alabama courts and argued Georgia was constitutionally required to honor that limitation under the Full Faith and Credit Clause.
- The Georgia trial court rejected the plea in abatement and entered judgment for George; the Georgia Court of Appeals affirmed.

## Issues

1. Whether the Full Faith and Credit Clause required Georgia courts to decline jurisdiction over an Alabama-created transitory cause of action because Alabama’s statute purported to confine suit to Alabama courts.

## Decision

- The Supreme Court affirmed the Georgia Court of Appeals.
- Georgia did not violate the Full Faith and Credit Clause by enforcing the Alabama statutory cause of action despite Alabama’s in-state-only venue provision.
- Alabama could not create a transitory cause of action and simultaneously prevent suit on it in any other court that otherwise had jurisdiction over the parties.
- The venue restriction was treated as a procedural direction, not a condition that was part of the substantive right.

## Legal Principles

- Full Faith and Credit requires enforcement of sister-state substantive rights and any conditions that are part of the right itself, but it does not compel adoption of a sister state’s purely procedural or venue rules.
- A transitory cause of action may be litigated in another state’s courts when they have jurisdiction over the parties, even if the creating state’s statute states the action “must be brought” only in its own courts.
- A state’s statute cannot, by extraterritorial operation, control the jurisdiction of courts in other states over transitory claims.

## Conclusion

The Court held that Georgia could hear and enforce an Alabama statutory employer-liability claim because the Full Faith and Credit Clause does not obligate a forum to apply another state’s in-state-only venue directive to a transitory cause of action.


Tennessee Coal, Iron & R.R. Co. v. George, 233 U.S. 354 (1914)