## Facts

- A bank obtained a Colorado money judgment against Lamb in 1927.
- In 1945, the judgment was revived in Colorado after personal service on Lamb in Missouri.
- The bank sued in Missouri to enforce the revived Colorado judgment.
- Missouri statutes limited a judgment’s life to ten years after rendition or revival and barred revival more than ten years after rendition, applying these rules to in-state and out-of-state judgments.
- The Missouri Supreme Court assumed the Colorado revivor was valid under Colorado law but refused enforcement because Missouri would not allow revival so long after the original judgment.

## Issues

1. Whether a state court decision rejecting a Full Faith and Credit claim is reviewable in the Supreme Court by appeal or by certiorari, and whether the application was timely when the deadline fell on a Sunday or legal holiday.
2. Whether the Full Faith and Credit Clause permits Missouri to refuse enforcement of a Colorado judgment revived in Colorado because Missouri’s own law would not have permitted revival after ten years.

## Decision

- The Court treated the improperly filed appeal papers as a petition for certiorari, granted certiorari, reversed, and remanded.
- It held the application was timely because when the last filing day falls on a Sunday or legal holiday, filing on the next business day is timely.
- It held Missouri’s refusal to give effect to the revived Colorado judgment, on the stated ground, violated the Full Faith and Credit Clause.
- It left open on remand whether the 1945 revivor was effective under Colorado law and whether the service used to revive the judgment satisfied due process.

## Legal Principles

- A state judgment determining a claimed right under the Full Faith and Credit Clause is reviewable in the Supreme Court by certiorari; papers filed as an appeal may be treated as a certiorari petition.
- When the last day to seek Supreme Court review falls on a Sunday or legal holiday, filing the next business day is timely under applicable federal timing rules.
- If a judgment is valid and enforceable in the rendering state, a sister state must generally accord it full faith and credit and may not deny enforcement solely because the forum’s own revival or limitations policy is more restrictive.
- A revivor that has the effect of a new judgment in the rendering state must be respected as such for full faith and credit purposes, subject to unresolved questions of the revivor’s validity and due process.

## Conclusion

The Supreme Court required Missouri to recognize a Colorado judgment revived under Colorado law, holding that Missouri could not defeat full faith and credit by applying its own stricter revival limits, while remanding for determination of the revivor’s status under Colorado law and the sufficiency of service under due process.


Union Nat'l Bank v. Lamb, 337 U.S. 38 (1949)