Facts
- Cheek Wells was killed in Alabama when a grinding wheel he was using burst.
- The wheel was manufactured by Simonds Abrasive Company, a Pennsylvania-based corporation.
- The administratrix of Wells’s estate sued in federal court in Pennsylvania under Alabama’s wrongful-death statute.
- Alabama’s wrongful-death statute required suit within two years of death.
- Pennsylvania’s wrongful-death limitation period required suit within one year of death.
- The suit was filed after one year but within two years of the death.
Issues
- Whether the Full Faith and Credit Clause requires a forum state to apply the limitation period contained in a sister state’s wrongful-death statute, rather than the forum’s shorter limitation period.
- Whether a forum violates Full Faith and Credit by applying its own statute of limitations to bar enforcement of a sister-state wrongful-death right that would be timely in the originating state.
Decision
- The Supreme Court affirmed judgment for Simonds Abrasive Company.
- The Court held that Pennsylvania’s conflicts rule applying the forum’s statute of limitations did not violate the Full Faith and Credit Clause.
- The Court held the result was not changed by the fact that the Alabama wrongful-death statute both created the right and specified a longer filing period.
- The Court found no unconstitutional discrimination because Pennsylvania applied its one-year limit uniformly to wrongful-death actions, regardless of where they arose.
Legal Principles
- A state may apply its own statute of limitations to an action brought in its courts to enforce a right created by another state, consistent with Full Faith and Credit.
- Full Faith and Credit does not require a forum to adopt a different limitation period merely because it is contained within a foreign statute that creates a cause of action unknown to the common law.
- Full Faith and Credit constraints are more likely implicated where a forum treats sister-state causes of action worse than comparable local actions; a neutral, generally applicable limitations rule is constitutionally permissible.
Conclusion
The Court upheld Pennsylvania’s application of its one-year wrongful-death limitation to bar an Alabama wrongful-death claim filed in Pennsylvania after one year, holding that the Full Faith and Credit Clause does not require the forum to use the longer limitations period contained in the sister state’s statute when the forum’s time bar is applied evenhandedly.