bakeret al general motors argued october decided january held elwell may testify missouri action without offense national full faith credit command pp animating purpose constitution full faith 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 milwaukee county white judgments full faith credit obligation exacting final judgment one state rendered adjudicatory authority subject matter persons governed judgment qualifies recognition throughout land see matsushita elec industrial epstein may guided forum state public policy determining law applicable controversy see nevada hall decisions support roving public policy exception full faith credit due judgments see estin estin assuming existence ubiquitous public policy exception permitting one state resist recognition another judgment district bakers action misread precedent never placed equity decrees outside full faith credit domain equity decrees payment money long considered equivalent judgments law entitled nationwide recognition see barber barber reason preclusive effects adjudication parties privity claim preclusion issue preclusion differ depending solely upon type relief sought civil action jackson concurring full faith credit however mean enforcement measures must travel sister state judgment preclusive effects measures remain subject control forum law see mcelmoyle ex rel bailey cohen pet orders commanding action inaction denied enforcement sister state purported accomplish official act within exclusive province state interfered litigation ordering state authority see fall eastin pp background principles view turns dimensions order gm relies upon stop elwell testimony asks matters michigan injunction legitimately conclude although michigan order claim preclusive elwell gm michigan judgment reach beyond controversy control proceedings gm brought parties asserting claims merits michigan considered michigan power parties basis commanding become intervenors dispute see martin wilks essentially although michigan decree operate elwell preclude volunteering testimony another jurisdiction michigan entering injunction elwell gm stipulated dictate another jurisdiction evidence relevant bakers controversy michigan inadmissible conclusion creates general exception full faith credit command surely permit state refuse honor sister state judgment based forum choice law policy preferences simply recognizes however mechanisms enforcing judgment travel judgment purposes full faith credit one state judgment automatically transfer title land another state similarly michigan decree determine evidentiary issues lawsuit brought parties subject jurisdiction michigan cf nixon language consent decree excluding scope thenpending georgia action informative michigan order interfered georgia jurisdiction michigan ban way interfere jurisdiction courts similar cases gm recognized interference potential consent decree agreeing institute contempt proceedings elwell giving subpoenaed testimony elsewhere gm ruled resort entered injunction telling injunctions ordinarily enforced enjoining surrogate tribunal pp reversed remanded ginsburg delivered opinion rehnquist stevens souter breyer joined scalia filed opinion concurring judgment kennedy filed opinion concurring judgment thomas joined notice opinion subject formal revision publication preliminary print reports readers requested notify reporter decisions washington typographical formal errors order corrections may made preliminary print goes press kenneth lee baker steven robert baker next friend melissa thomas general motorscorporation writ certiorari appeals eighth circuit january justice ginsburg delivered opinion case concerns authority one state order witness testimony shall heard settlement claims counterclaims precipitated discharge ronald elwell former general motors corporation gm engineering analyst gm paid elwell undisclosed sum money parties agreed permanent injunction stipulated gm elwell entered michigan county injunction prohibited elwell testifying without prior written consent gm witness kind litigation already filed filed future involving gm owner seller manufacturer designer gm separately agreed however elwell ordered testify tribunal testimony actionable violation michigan injunction agreement entry stipulated injunction michigan elwell subpoenaed testify product liability action commenced missouri plaintiffs involved michigan case question presented whether national full faith credit command bars elwell testimony missouri case hold elwell may testify missouri action without offense full faith credit requirement two lawsuits initiated different parties different gave rise full faith credit issue us one suit involved severed employment relationship complaint describe controversy turn centuryschoolbook italic suit elwell general motors ronald elwell gm employee fifteen years beginning elwell assigned engineering analysis group studied performance gm vehicles particularly vehicles involved product liability litigation elwell studies research concentrated vehicular fires assisted improving performance gm products suggesting changes fuel line designs course employment elwell frequently aided gm lawyers engaged defending gm product liability actions beginning employment relationship soured gm elwell first negotiated agreement elwell retire serving gm consultant two years time came elwell retire however disagreement surfaced continued may plaintiffs product liability action pending georgia deposed elwell georgia case involved gm pickup truck fuel tank burst flames collision deposition objection counsel gm elwell gave testimony differed markedly testimony given serving expert witness gm specifically elwell several times defended safety crashworthiness pickup fuel system deposition georgia action however elwell testified gm pickup truck fuel system inferior comparison competing products month later elwell sued gm michigan county alleging wrongful discharge tort contract claims gm counterclaimed contending elwell breached fiduciary duty gm disclosing privileged confidential information misappropriating documents response gm motion preliminary injunction hearing michigan trial november enjoined elwell consulting discussing disclosing person general motors corporation trade secrets confidential information matters work product relating manner subject matter products liability litigation whether already filed filed future ronald elwell received knowledge entrusted employments general motors corporation august gm elwell entered settlement elwell received undisclosed sum money parties also stipulated entry permanent injunction jointly filed michigan stipulation injunction proposed permanent injunction contained two proscriptions first substantially repeated terms preliminary injunction second comprehensively enjoined elwell testifying without prior written consent general motors corporation either upon deposition trial expert witness witness kind consulting attorneys agents litigation already filed filed future involving general motors corporation owner seller manufacturer designer product issue encompassing bar consent injunction made exception provision shall operate interfere jurisdiction georgia litigation involving fuel tank still pending ibid emphasis added noninterference provision appears stipulated decree august hearing michigan entered injunction precisely tendered parties although stipulated injunction contained exception georgia action pending elwell gm included separate settlement agreement general limitation tribunal ordered elwell testify testimony way support gm action violation injunction settlement agreement agreed elwell appearance testimony hearings motions quash subpoena deposition trial official pro ceeding tribunal orders permanent injunction agreement ment agreement quoted six years since settlement elwell testified gm georgia pursuant exception contained injunction several jurisdictions elwell subpoenaed testify centuryschoolbook italic suit bakers general motors described employment termination litigation next summarize complaint underlying case decedent beverly garner passenger chevrolet blazer involved february missouri highway accident blazer engine caught fire driver passenger died september garner sons kenneth steven baker commenced wrongful death product liability action gm missouri state bakers alleged faulty fuel pump blazer caused engine fire killed mother gm removed case federal basis parties diverse citizenship merits gm asserted fuel pump neither faulty cause fire collision impact injuries alone caused garner death bakers sought depose elwell call witness trial gm objected elwell appearance deponent trial witness ground michigan injunction barred testimony response bakers urged michigan injunction override missouri subpoena elwell testimony bakers noted settle ment agreement elwell testify ordered testimony actionable violation michigan injunction camera review michigan injunction settlement agreement federal district missouri allowed bakers depose elwell call witness trial responding gm objection district stated alternative grounds ruling michigan injunction need enforced blocking elwell testimony violate missouri public policy shielded disclosure privileged otherwise confidential information injunction modified michigan elsewhere modify decree trial elwell testified support bakers claim alleged defect fuel pump system contributed postcollision fire addition identified described internal gm memorandum bearing risk engine fires following trial jury awarded bakers million damages district entered judgment jury verdict appeals eighth circuit reversed district judgment ruling inter alia elwell testimony admitted assuming arguendo existence public policy exception full faith credit command appeals concluded district erroneously relied missouri policy favoring disclosure relevant nonprivileged information see id missouri equally strong public policy favor full faith credit eighth circuit also determined evidence insufficient show michigan modify injunction barring elwell testimony see appeals observed michigan asked several occasions modify injunction yet noted michigan intend block elwell testimony cases like bakers injunction unnecessary id granted certiorari decide whether full faith credit requirement stops bakers parties michigan proceeding obtaining elwell testimony missouri wrongful death action ii constitution full faith credit clause provides full faith credit shall given state public acts records judicial proceedings every state congress may general laws prescribe manner acts records proceedings shall proved effect thereof acts records judicial proceedings copies thereof authenticated shall full faith credit every within territories possessions law usage courts state ter ritory possession taken 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 see also estin estin full faith credit clause substituted command earlier principles comity thus basically altered status independent sovereigns precedent differentiates credit owed laws legislative measures common law judgments numerous cases held credit must given judgment another state although forum required entertain suit judgment founded milwaukee county full faith credit clause compel state substitute statutes statutes dealing subject matter concerning competent legislate pacific employers ins trial accident see phillips petroleum shutts regarding judgments however full faith credit obligation exacting final judgment one state rendered adjudicatory authority subject matter persons governed judgment qualifies recognition throughout land claim issue preclusion res judicata purposes words judgment rendering state gains nationwide force see matsushita elec industrial epstein kremer chemical constr see also reese johnson scope full faith credit judgments colum rev may guided forum state public policy determining law applicable controversy see nevada hall decisions support roving public policy exception full faith credit due judgments see estin full faith credit clause ordered submission even hostile policies reflected judgment another state practical operation federal system constitution designed demanded fauntleroy lum judgment missouri entitled full faith credit mississippi even missouri judgment rested misapprehension mississippi law assuming existence ubiquitous public policy exception permitting one state resist recognition another state judgment district bakers action see supra misread precedent full faith credit clause one provisions incorporated constitution framers purpose transforming aggregation independent sovereign nation sherrer sherrer aware considerations local policy law rightly deemed impair force effect full faith credit clause act congress require given money judgment outside state rendition magnolia petroleum hunt never placed equity decrees outside full faith credit domain equity decrees payment money long considered equivalent judgments law entitled nationwide recognition see barber barber unconditional adjudication petitioner right recover sum money entitled full faith credit see also ehrenzweig conflict laws rev ed describing indefensible old doctrine equity decree merge claim judgment qualify recognition see reason preclusive effects adjudication parties privity claim preclusion issue preclusion res judicata collateral estoppel differ depending solely upon type relief sought civil action cf barber jackson concurring full faith credit clause implementing statute speak judgments proceedings without limitation fed rule civ proc providing one form action known action lieu discretely labeled actions law suits equity full faith credit however mean must adopt practices regarding time manner mechanisms enforcing judgments enforcement measures travel sister state judgment preclusive effects measures remain subject control forum law see mcelmoyle ex rel bailey cohen pet judgment may enforced laws enforcing forum may permit see also restatement second conflict laws local law forum determines methods judgment another state orders commanding action inaction denied enforcement sister state purported accomplish official act within exclusive province state interfered litigation ordering state authority thus sister state decree concerning land ownership another state held ineffective transfer title see fall eastin although decree may indeed preclusively adjudicate rights obligations running parties foreign litigation see robertson howard may doubted equity one state proper case compel defendant convey property situated another antisuit injunctions regarding litigation elsewhere even compatible due process direction constraining parties decree see cole cunningham fact controlled second actions regarding litigation see james grand trunk western see also scoles hay conflict laws ed observing antisuit injunction address thus preclusive effect merits litigation second forum sanctions tions injunction event generally administered issued injunction see stiller hardman nonrendition forum enforces monetary relief portion judgment leaves enforcement injunctive portion rendition forum background principles view turn dimensions order gm relies upon stop elwell testimony specifically take question matters michigan injunction legitimately conclude earlier recounted see supra parties michigan county elwell gm submitted injunction presiding judge signed issue joined expressly litigated determined michigan proceeding order claim preclusive elwell gm elwell claim wrongful discharge related contract tort claims merged judgment sue recover see parklane hosiery shore doctrine res judicata judgment merits prior suit bars second suit involving parties privies based cause action see also restatement second judgments similarly gm sue elwell elsewhere counterclaim gm asserted michigan see id comment defendant interposes counterclaim substance plaintiff far counterclaim concerned plaintiff substance michigan judgment however reach beyond controversy control proceedings gm brought parties asserting claims merits michigan considered michigan power parties basis commanding become intervenors elwellgm dispute see martin wilks essentially michigan lacks authority control courts elsewhere precluding actions brought strangers michigan litigation determining witnesses competent testify evidence relevant admissible search truth see restatement second conflict laws rev forum law governs witness competence grounds excluding evidence cf soci nationale industrielle dist southern dist iowa foreign blocking statute barring disclosure certain information es deprive american power order party subject jurisdiction produce information first city bank ca new york bank may refuse produce records german branch even though might subject bank civil liability german law district recognized michigan decree operate elwell preclude volunteering testimony see app pet cert michigan entering injunction elwell gm stipulated dictate another jurisdiction evidence relevant bakers controversy michigan inadmissible conclusion creates general exception full faith credit command surely permit state refuse honor sister state judgment based forum choice law policy preferences rather simply recognize mechanisms enforcing judgment travel judgment purposes full faith credit see mcelmoyle ex rel bailey cohen pet see also restatement second conflict laws one state judgment automatically transfer title land another state see fall eastin similarly michigan decree determine evidentiary issues lawsuit brought parties subject jurisdiction michigan cf nixon xceptions demand every man evidence lightly created expansively construed derogation search language consent decree informative regard excluding georgia action ban testimony elwell without gm permission decree provides shall operate interfere jurisdiction georgia elwell general motors wayne cty order dismissing plaintiff complaint granting permanent injunction app emphasis added michigan order extended georgia case interfer ed jurisdiction georgia michigan ban way interfere jurisdiction courts cases similar one pending georgia line recognition interference potential consent decree gm provided settlement agreement another ordered elwell testify testimony way render vulnerable suit michigan violation injunction agreement see eighth circuit regarded settlement agreement provision merely concession gm courts might fail extend full faith credit michigan injunction ibid explained however michigan power reach missouri courtroom displace forum determination whether admit exclude evidence relevant bakers case light see altruism gm agreement institute contempt proceedings elwell michigan giving subpoenaed testimony elsewhere rather find telling gm ruled resort entered injunction injunctions ordinarily enforced enjoining surrogate tribunal see supra sum michigan authority shield witness another jurisdiction subpoena power case involving persons causes outside michigan governance recognition full faith credit owed dispositions michigan authority order michigan decree command obedience elsewhere matter michigan lacks authority resolve see thomas washington gas light plurality opinion full faith credit must given determination state tribunal authority make parity reasoning full faith credit need given determinations power reasons stated judgment appeals eighth circuit reversed case remanded proceedings consistent opinion ordered notes judge new case judge conducted hearing preliminary injunction stage presided settlement stage entered permanent injunction conflict eighth circuit many lower courts permitted elwell testify nonprivileged matters see addendum brief petitioners citing cases predating constitution articles confederation contained provision order full faith credit shall given records acts judicial proceedings courts magistrates every state articles confederation art iv concise history full faith credit see jackson full faith lawyer clause constitution colum rev first congress enacted original full faith credit statute may see act may ch stat codified amended said records judicial proceedings authenticated aforesaid shall faith credit given every within law usage courts state whence said records shall although text statute revised since command full faith credit judgments remained constant res judicata term traditionally used describe two discrete effects call claim preclusion valid final adjudication claim precludes second action claim part see restatement second judgments issue preclusion long called collateral estoppel issue fact law actually litigated resolved valid final judgment binds parties subsequent action whether different claim see id use plain english terms claim issue preclusion lieu res judicata collateral estoppel see migra warren city school dist bd see also paulsen sovern public policy conflict laws colum rev noting traditional dubious use term public policy obscure assertion forum right law applied controversy forum relationship see supra wright miller cooper federal practice procedure although second state need directly enforce injunction entered another state may often required honor issue preclusion effects first congress provided interdistrict registration federal judgments recovery money property upon registration judgment shall effect judgment district district registered may enforced like manner similar interstate registration procedure effective result widespread adoption revised uniform enforcement foreign judgments act see id supp table listing adoptions district columbia held impermissible state enjoin party proceeding federal see donovan dallas yet ruled credit due state injunction barring party maintaining litigation another state see ginsburg judgments search full faith credit rule conflicting judgments harv rev see also reese full faith credit foreign equity decrees iowa rev urging although yet occasion determine issue full faith credit require dismissal action whose prosecution enjoined hold otherwise mean effect courts one state control goes courts another state courts dealt question main regarded antisuit injunctions outside full faith credit ambit see id see also id current state law permitting antisuit injunction issue compelling deference outside rendering state may reasonable compromise extreme alternatives general rule respect antisuit injunctions running state courts general rule denying authority issue injunctions directed proceedings gm emphasizes key factor warranting injunction elwell inability assure testimony might give steer clear knowledge gained protected confidential communications see brief respondent see also id contending elwell testimony pervasively uncontrollably leavened general motors privileged information petitioners assert gm dispute however point elwell testimony bakers action gm object question answer grounds product trade secrets privilege see brief petitioners event observed issue preclusion invoked one participate prior adjudication see laboratories university foundation hansberry lee thus justice kennedy emphasizes obvious noting michigan judgment preclusive effect bakers parties michigan litigation see post observation misses thrust gm argument gm readily acknowledges commonplace rule person may bound judgment personam case made party brief respondent gm adds michigan decree bind bakers binds elwell forcibly gm insists bakers object binding effect gm seeks michigan judgment bakers constitutionally protected interest obtaining testimony particular witness see id party injunction elwell holding legal obligations violate anyone due process given argument clear issue preclusion principles standing alone resolve controversy gm presents justice kennedy inexplicably reads decision sweeping exception full faith credit based solely integrity missouri judicial processes post michigan judgment entitled full faith credit endeavored make plain impermissibly interferes missouri control litigation brought parties michigan thus justice kennedy hypothetical see ibid misses mark bakers parties michigan proceedings actually litigated privileged character elwell testimony bakers course precluded relitigating issue missouri see cromwell county sac etermination question directly involved one action conclusive question second suit parties see also supra kenneth lee baker steven robert baker next friend melissa thomas general motorscorporation writ certiorari appeals eighth circuit january justice scalia concurring judgment agree enforcement measures travel judgments preclusive effects ante long established judgment state enforced state execution issued within mcelmoyle ex rel bailey cohen pet recite principle decide case general motors asked district missouri enforce michigan injunction missouri obliged enforce michigan injunction preventing elwell presenting testimony obliged enforce holding elwell contempt full faith credit clause make judgments domestic judgments intents purposes gave general validity faith credit evidence execution issue upon judgments without new suit tribunals thompson whitman wall emphasis added quoting story conflict laws judgment decree one state sure may grounds action defense one clause implementing statute establish rule evidence rather jurisdiction make record judgment rendered due notice one state conclusive evidence courts another state matter adjudged affect jurisdiction either judgment rendered offered evidence judgments recovered one state union proved courts another government whether state national within differ judgments recovered foreign country respect reexaminable merits impeachable fraud obtaining rendered jurisdiction cause judgment general motors obtained michigan carry another state efficacy judgment upon property persons enforced execution give force judgment another state must made judgment executed latter laws may permit lynde lynde quoting mcelmoyle supra see watts waddle pet case involving suit obtain equity decree ordering conveyance land duplicating decree already issued another state neither full faith credit clause implementing statute requires missouri execute injunction issued courts michigan concur judgment kenneth lee baker steven robert baker next friend melissa thomas general motorscorporation writ certiorari appeals eighth circuit january justice kennedy justices thomas join concurring judgment concur judgment view case controlled full faith credit principles render majority extended analysis unnecessary due respect problematic degree separate opinion explains approach majority course correct hold judgment presented courts second state may denied enforcement based upon disagreement laws state rendition full faith credit forbids second state questioning judgment grounds little doubt proposition often recognized second state obligation give effect another state judgments even law underlying judgments contravenes public policy second state see estin estin sherrer sherrer magnolia petroleum hunt williams north carolina fauntleroy lum concern majority stated principle proceeds disregard announcing two broad exceptions first majority allow courts outside issuing state decline enforce judgments purport ing accomplish official act within exclusive province sister state ante second basic rule full faith credit said cover injunctions interfer ing litigation ordering state authority ante exceptions majority recognizes neither consistent rejection public policy exception full faith credit accord established rules implementing full faith credit clause employed resolve case furthermore exceptions full faith credit potential disrupting judgments give us considerable pause decisions careful foreclose effect types injunctions majority place outside ambit full faith credit authorities seem disregarded today holding example majority chooses discuss extent courts may compel conveyance property jurisdictions subject proven quite difficult cases uphold actions state courts affecting land outside territorial reach robertson howard may doubted equity one state proper case compel defendant convey property situated another state see also carpenter strange muller dows massie watts cranch see generally wright miller kane federal practice procedure pp ed restatement second conflict laws comment reese full faith credit foreign equity decrees iowa rev undertaken today announce exception denies full faith credit based principle prior judgment interferes litigation pending another jurisdiction see cole cunningham simon southern cf baltimore ohio kepner donovan dallas harlan dissenting see generally reese supra yet occasion determine whether practice ignoring antisuit injunctions consistent full faith credit general matter disagreement among state courts duty recognize decrees enjoining proceedings courts see schopler extraterritorial recognition propriety counterinjunction injunction actions courts supp subjects fundamental delicate addressed case necessarily requiring discussion even caution lest announce rules sound later application see restatement supra comment occasion determine whether full faith credit requires state enforce valid judgment sister state orders act payment money enjoins act scoles hay conflict laws ed noting interstate recognition equity decrees divorce decrees decrees ordering payment money matter uncertainty might required hold future case raises issue otherwise valid judgment intrude upon essential processes courts outside issuing state certain narrow circumstances need announce define principle even qualification full faith credit required judicial processes second state sought controlled procedural institutional aspects discussion provide sufficient guidance exception construed light precedents majority broad review matters articulate rationale underlying conclusions absence elaboration unclear particular injunction renders undeserving full faith credit reliance upon unidentified principles justify omitting certain types injunctions doctrine application leaves decision uneasy tension rejection broad public policy exception full faith credit following example illustrates uncertainty surrounding majority approach suppose bakers anticipated need elwell testimony missouri appeared michigan litigate privileged character testimony sought elicit assume law privilege jurisdictions elwell gm bakers michigan michigan law gave injunction preclusive effect bakers relitigate point general principles issue preclusion control perhaps argument made majority appears say integrity missouri judicial processes demands rule allowing relitigation issue reasons given need confront interesting question event rule exception full faith credit requires courts provide direct enforcement judgments issued also requires federal courts give preclusive effect state judgments judg ments given courts state judgments emerged kremer chemical constr accord parsons steel first alabama bank marrese american academy orthopaedic surgeons migra warren city school dist bd haring prosise allen mccurry full faith credit local doctrines res judicata speaking generally become part national jurisprudence riley new york trust whether injunction enforceable another state terms courts second state required honor issue preclusive effects see parsons steel supra wright miller cooper federal practice procedure ii case us course bakers neither parties earlier litigation subject jurisdiction michigan courts majority pays scant attention circumstance becomes critical beginning point full faith credit analysis requires determination effect judgment courts issuing state recent full faith credit cases said determining force effect judgment first step analysis matsushita elec industrial epstein marrese supra haring supra see also kremer supra state courts give preclusive effect prior judgment courts accord greater efficacy haring supra quoting union planters bank memphis accord marrese con clusion issuing state give prior judgment preclusive effect ends inquiry making unnecessary determine existence exceptions full faith credit decline inquire questions inquiry obviate new extensions exceptions full faith credit see haring supra honor undoubted principle courts need give prior judgment force effect issuing state gives case us resolved appeals parties arguments seemed embrace assumption michigan apply full force judgment bakers michigan law appear support assumption simple fact bakers parties michigan proceedings nothing indicates michigan make novel assertion earlier injunction binds bakers party subject jurisdiction collateral estoppel apply michigan law parties must full opportunity litigate issue must mutuality estoppel nummer treasury quoting storey meijer cert denied although trend modern law abolish requirement mutuality reaffirmed commitment doctrine howell vito trucking excavating mutuality estoppel remains law jurisdiction lichon american universal ins omitted since bakers parties michigan proceedings opportunity litigate issues presented appears michigan law treat bound judgment majority cites authority contrary makes difference judgment question injunction michigan twice rejected arguments injunctions preclusive effect later litigation relying small part fact persons preclusion asserted parties earlier litigation bacon walden defendant party prior injunctive suit matter law affected bound decree rendered detroit detroit fact defendant way party record sufficient answer contention holding circuit judge prior injunctive case controlling determination present opinion appeals suggests michigan issued injunction intended bind third parties litigation question however trial intended particular case preclusive effect judgment controlling legal principles state full faith credit measures effect judgment laws rendering state including authoritative rulings state highest questions issue preclusion jurisdiction third parties see kremer supra matsushita supra fact michigan trial courts refused reconsider injunction instead required litigants return trial issued first place sheds little light substance issue preclusion law michigan construing state law must determine highest state decide issue see king order commercial travelers amer ica commissioner estate bosch case moreover michigan trial courts declined modify injunction appear base rulings preclusion law relied instead michigan rule directs parties wishing modify injunction present arguments entered see brief respondent rule procedural rule based comity concerns preclusion rule reflects michigan determination within state michigan respect issuing judicial resources best preserved allowing issuing determine whether injunction apply proceedings procedural rule binding courts another state virtue full faith credit see sun oil wortman state may apply procedural rules actions litigated courts bakers never appeared michigan full faith credit used force subject michigan jurisdiction see baker baker eccles assume party resident beyond confines state required come within borders submit personal controversy tribunals upon receiving notice suit place residence futile attempt extend authority control state beyond territory michigan law burden persuasion rests party raising preclusion defense see detroit qualls finance simms light doctrines absence contrary authority one conclude gm carried burden showing michigan courts bind bakers terms earlier injunction prohibiting elwell testifying result come surprise unlikely michigan give judgment preclusive effect person party proceeding entered otherwise subject jurisdiction issuing see kremer previously recognized judicially created doctrine collateral estoppel apply party earlier decision asserted fair opportunity litigate claim issue although inconsistent point gm disavows desire issue preclude bakers claiming party injunction elwell see brief respondent difficult accept assessing preclusive reach judgment look practical effect martin wilks donovan dallas matter prohibition addressed parties rather federal oklahoma packing oklahoma gas elec injunction restraint parties formally directed state immaterial despite disclaimer gm seeks alter course suit bakers preventing bakers litigating admissibility elwell testimony furthermore even accept gm argument bakers essentially irrelevant dispute gm argument flawed terms elwell present litigation seek relitigate anything witness party events determining threshold matter extent michigan law gives preclusive effect injunction eliminates need decide whether full faith credit applies equitable decrees general matter extent general rules full faith credit subject exceptions michigan law seek bind bakers injunction suffices resolve case reasons concur judgment footnotes