milwaukee county white argued decided december herbert naujoks madison clark hazelwood milwaukee milwaukee county irving herriott chicago white justice stone delivered opinion case comes section judicial code certificate appeals seventh circuit presents question law concerning instructions desired proper decision case relevant facts stated certificate appellant milwaukee county county citizen wisconsin brought suit district northern illinois white company appellee corporation citizen illinois recover judgment appellant duly recovered entered appellee circuit milwaukee county general jurisdiction judgment siad taxes duly assessed appellee wisconsin statutes upon income received business transacted within state state license district dismissed cause ground suit substance brought enforce revenue laws wisconsin maintained district illinois question certified follows district state illinois jurisdiction parties entertain jurisdiction action therein brought based upon valid judgment rendered competent jurisdiction state wisconsin defendant judgment predicated upon income tax due defendant state wisconsin appellee insists question answered negative suit within judicial power conferred upon district courts constitution laws judgment taxes constitutes exception requirement constitution statutes full faith credit given state public acts judicial proceedings every state section judicial code district courts given original jurisdiction suits civil nature common law equity requisite diversity citizenship amount controversy exceeds grant jurisdiction causes arising state well federal law phrase civil nature used contradistinction offenses diction district courts restricted section offenses thus suits civil nature within meaning section involve criminal prosecution punishment character traditionally cognizable courts common law equity suits upon judgment foreign domestic civil liability jurisdiction cause parties maintainable common law upon writ debt indebitatus assumpsit even judgment deemed colored nature obligation whose validity establishes free find based obligation penal character refuse enforce outside state rendered see wisconsin pelican insurance et seq compare fauntleroy lum still obligation pay taxes penal statutory liability quasi contractual nature enforceable exclusive statutory remedy civil courts action debt indebitatus assumpsit chamberlin price dollar savings bank wall see stockwell wall meredith pet rule established english courts declaration independence attorney general weeks bunbury exch attorney general jewers batty bunbury exch attorney general hatton bunbury exch attorney general see comyn digest title chitty pleading cf attorney general sewell objection courts one state entertain suit recover taxes due another upon judgment taxes rightly addressed want judicial power courts authorized entertain civil suits law goes jurisdiction merits raises question district courts competent decide see illinois central adams general investment new york central becker steel cummings attorney general decided november defense without merit full faith credit must given judgment even full faith credit commanded nothing constitution laws requires state deny relief upon judgment taxes state conformity state policy may comity give remedy credit clause compel young masci bond hume cf tennessee coal iron george clark plastering seaboard surety herrick minneapolis louis ry healy root pick mass schuler schuler suit recover taxes due statutes another state allowed without regard compulsion full faith credit clause holshouser gold hill copper privilege may extended statute see laws suits enforce laws one state entertained courts another principle comity federal district courts sitting state may entertain infringe federal law policy union trust grosman bond hume supra northern pacific babcock dennick central see bradford electric light clapper faith credit required given judgments depend constitution alone article commands faith credit shall given state public acts records judicial proceedings every state adds may general laws prescribe manner acts records proceedings shall proved effect thereof congress exercised power act may usca provides manner proof judgments one state courts another specifically directs judgments faith credit given every within law usage courts state taken exception may command one implied nature dual system government recognizes consistently credit clause may limits extent policy one state many respects sovereign may subordinated policy another exceptions often pointed broderick rosner alaska packers industrial accident commission bradford electric light clapper supra huntington attrill wisconsin pelican insurance instances decided see haddock haddock maynard hill hood mcgehee olmsted olmsted fall eastin without attempting say limits may assume present purposes command constitution statute direct inquiry question whether state judgment taxes taken may policy enforcement meriting recognition permissible limitation upon credit clause question final arbiter see alaska packers association industrial accident commission supra bradford electric light clapper supra said answering examine record supports judgment refuse give credit judgment cause action upon founded one enforce appellee urges suit taxes imposed state statute entertained outside taxing state often cases statutes imposing taxes entitled full faith credit obligations pay money arising statutes one state must given recognition courts another converse hamilton broderick rosner supra bradford electric light clapper supra insisted rule taxing statutes constitute exception analogous ing penal laws courts one state called upon scrutinize relations foreign state citizens involved revenue laws thus commit state forum positions might seriously embarrassing neighbors see moore mitchell beale conflict laws whether one state must enforce revenue laws another remains open question see moore mitchell stop inquire whether considerations thought preclude enforcement penal laws one state courts another applicable taxing statutes whether mere possibility embarrassment enforcement stay hand another state cases fact embarrassment occur present purposes assume courts one state required entertain suit recover taxes levied statutes another confine inquiry single question whether must nevertheless give full faith credit judgments taxes cause action judgment different upon judgment entered suit upon money judgment civil cause action validity claim upon founded open inquiry whatever genesis regardless nature right gave rise judgment obligation pay money nature debt upon specialty recovery upon resisted grounds rendered without jurisdiction pennoyer neff ketchum tilt kelsey ceased obligatory payment discharge anderson clark haggerty amory allen mass first nat bank hahn revere copper dimock cause action state forum provided provision davis provision compare kenney lodge unless compelled privileges immunities clause const amend compare douglas new york mcknett louis ry broderick rosner supra possibly procured fraud compare christmas russell wall maxwell stewart wall wall hanley donoghue simmons saul webster reid ncnitt turner wall cole cunningham trial issues even though judgment taxes incurred laws another state requires scrutiny revenue laws relations established laws citizens calls pronouncement upon policy sister state involves embarrassment interstate rendition fugitives justice constitutional command specific requiring full faith credit foreign judgments liens entitled execution state brought see cohen pet cole cunningham supra cf gasquet fenner sistare sistare demand priority domestic claims taxes judgment upon simple contract debt equally binding obligation judgment debtor rendered full faith credit must accorded perceive greater possibility embarrassment litigating validity judgment taxes enforcing payment money purpose credit clause alter status several independent foreign sovereignties free ignore obligations created laws judicial proceedings others make integral parts single nation throughout remedy upon obligation might demanded right irrespective state origin purpose lightly set aside deference local policy exists seem trivial merit serious consideration weighed policy constitutional provision interest state whose judgment challenged circumstances disclosed state said legitimate policy payment neighbor taxes obligation judicially established courts whose judgments practically every instance must give full faith credit compare fauntleroy lum supra numerous cases held credit must given judgment another state although forum required entertain suit judgment founded considerations policy forum defeat suit upon original cause action involved suit upon judgment insufficient defeat full faith credit required given judgment another state although original suit based arose state forum barred statute limitations judgment rendered christmas russell wall roche mcdonald original suit upon gambling contract invalid law forum made fauntleroy lum supra required judgment wrongful death although thought statute giving recovery entitled full faith credit kenney lodge supra compare converse hamilton supra broderick rosner supra see also american express mullins appellee especially relies upon statement opinion wisconsin pelican insurance supra essential nature real foundation cause action changed recovering judgment upon technical rules regard original claim merged judgment judgment implying promise defendant pay preclude judgment presented affirmative action go behind judgment purpose examining validity claim ascertaining whether claim really one nature authorized enforce case held without original jurisdiction suit brought wisconsin recover upon judgment obtained courts penalty imposed statutes failure insurance company file annual report far opinion taken suggest full faith credit required respect judgment unless original cause action entitled like credit inconsistent decisions already noted discredited fauntleroy lum supra kenney lodge supra precise question presented appears decided single case people state new york coe manufacturing law holding case new york judgment taxes entitled full faith credit new jersey errors appeals pointed questions construction application new york tax laws subject litigation new jersey since conclusively determined new york judgment established liability tax conclude judgment denied full faith credit state federal courts merely taxes intimate opinion whether suit upon judgment obligation created penal law international sense see huntington attrill supra within jurisdiction federal district courts whether full faith credit must given judgment even though suit penalty reduced judgment maintained outside state imposed see wisconsin pelican insurance supra findings wisconsin upon judgment present case predicated appended exhibit certificate indicate judgment included interest per cent delinquency payment record disclose nominal penalty arose penal law nature preclude suit recover outside state wisconsin see huntington attrill et certificate question framed assumption judgment stated taxes question answered justice mcreynolds justice butler think question answered footnotes answer certified questions conformed horsy daniel lev marsh prince nicholson taunt hall obder east lyman brown fed cas curt taylor bryden johns russell smyth andrews montgomery johns boston india rubber factory hoit carter crews port belford woodward cole driskell blackf ind see chitty pleading freeman judgments henry sargeant gulledge lumber wenatchee land state colorado harbeck james second russian insurance martin beadall moore cf municipal council sydney bull queen holland drukker ch attorney general canada schulze moore mitchell affirmed another ground anita bliss estate misc martin estate misc state maryland turner misc contra holshouser gold hill copper restatement conflict laws american law institute declares action maintained right created law foreign state method furthering governmental interests stated comment refer claims taxes also declares valid foreign judgment payment money obtained favor state state agency private person cause action created law foreign state method furthering governmental interests enforced comment enforcement judgment required credit clause illustration state judgment foreign corporation stipulated fee privilege business within state entitled full faith credit conclusions compared new york coe manufacturing supra see beale conflict laws