Power of Congress to prescribe state rules of evidence.

- Aside from the full faith and credit clause of the Constitution, Congress would have no power to prescribe rules of evidence for state courts. Edmonds v. State, 201 Ga. 108, 39 S.E.2d 24 (1946).

Full faith and credit clause does not apply to judgments of foreign countries. Cocke v. Truslow, 91 Ga. App. 645, 86 S.E.2d 686 (1955).

Application only to judgments obtained within courts of the United States.

- Comity alone could authorize recognition of a Mexican divorce. The general comity rule is that in a proper case the laws and judicial proceedings of one state will be enforced in another state, provided they do not involve anything immoral, contrary to public policy, or violative of the conscience of the state called upon to give them effect. It is fundamental that comity will not be applied where a divorce is obtained in a foreign state under circumstances which offend the public policy of this state as found in its Constitution and statutes and the decisions of its courts. Christopher v. Christopher, 198 Ga. 361, 31 S.E.2d 818 (1944).

English court decree accorded conclusive effect.

- A decree of an English court of chancery, rendered when both parties were citizens of that realm, which adjudges that the defendant therein is liable to the plaintiff in a given sum of money, no question being raised as to the court having jurisdiction of the subject matter or of the parties, and there being no suggestion of fraud in its rendition, will be given conclusive effect by the courts of this state. Coulborn v. Joseph, 195 Ga. 723, 25 S.E.2d 576 (1943).

Full faith and credit will be accorded a foreign decree only when properly proved. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Manner of proving foreign judgments limited by federal statute.

- A state cannot by merely failing or refusing to amend its code place greater restrictions upon a party seeking to rely on a foreign judgment than are imposed by the procedure enacted by Congress pursuant to the full faith and credit clause of the United States Constitution. Peeples v. Peeples, 103 Ga. App. 462, 119 S.E.2d 710 (1961).

Copy of foreign judgment only required in action based thereon.

- To maintain an action based on judgment from another state, it is not necessary to show an authenticated copy of the record of the entire divorce and alimony proceedings; but a prima facie case is made by pleading and proving a properly authenticated copy of the judgment itself. Creaden v. Krogh, 75 Ga. App. 675, 44 S.E.2d 136 (1947).

Certification of copy of foreign judgment by associate judge sufficient.

- A copy of the judgment of a court of a sister state attested by the clerk of such court with a certificate by one of the judges of the court that such attestation is in due form is sufficient to authorize its admission in evidence even though the judge signing the certificate was not the chief or presiding judge of such court. Peeples v. Peeples, 103 Ga. App. 462, 119 S.E.2d 710 (1961).

Full faith and credit clause does not compel state to adopt any particular set of rules of conflict of laws; it merely sets certain minimum requirements which each state must observe when asked to apply the law of a sister state. Crider v. Zurich Ins. Co., 380 U.S. 39, 85 S. Ct. 769, 13 L. Ed. 2d 641 (1965).

Mandatory judicial recognition of laws and legal proceedings of sister states.

- The courts of this state must judicially recognize the laws of the several states, as published by authority, without proof, and properly authenticated judicial proceedings of a sister state are entitled to the same full faith and credit as they have by law or usage in the courts of the state from which they are taken. Kelly v. Kelly, 115 Ga. App. 700, 155 S.E.2d 732 (1967).

Foreign judgment entitled to same effect as foreign jurisdiction gives it.

- Lawfully obtained judgments of the court of one state, when sued on or pleaded or introduced in evidence in another state are entitled to receive the same full faith, credit, and respect that they are accorded in the state where rendered. Earley v. Earley, 165 Ga. App. 483, 300 S.E.2d 814 (1983).

Foreign judgment subject to attack for lack of jurisdiction or fraud only.

- Under the full faith and credit clause of the United States Constitution a judgment of a foreign court will be enforced by the courts of this state unless it is shown that the foreign court lacked jurisdiction of the person or subject matter or that the judgment was procured by fraud. Earley v. Earley, 165 Ga. App. 483, 300 S.E.2d 814 (1983).

Ex parte application for letters of administration.

- Georgia court was not required to give full faith and credit to any findings or presumptions made by a New Jersey court on the issue of domicile in a proceeding which amounted to no more than an ex parte application for letters of administration of an estate. Wilson v. Willard, 183 Ga. App. 204, 358 S.E.2d 859 (1987).

Contractual provision that is not valid where made does not become part of the contract between the parties. GECC v. Home Indem. Co., 168 Ga. App. 344, 309 S.E.2d 152 (1983).

Conviction not precluded based on notice.

- While out of state convictions must be given the same faith and credit to which they are entitled in the state where they are rendered, the full faith and credit clause does not prevent Georgia from according felony status in Georgia to out-of-state misdemeanor criminal convictions in those instances where the Georgia statute provides sufficient notice to persons of ordinary intelligence than any out-of-state misdemeanor convictions that meet the specified statutory requirements will be deemed the equivalent of a felony conviction in Georgia. Thus, since the defendant was charged with being a convicted felon in possession of a firearm, contrary to O.C.G.A. § 16-11-131, based on a misdemeanor involuntary manslaughter conviction in another state, for which the maximum penalty was five years imprisonment, if the statute had provided defendant adequate notice that the defendant's misdemeanor conviction could be used as a predicate for this charge, the full faith and credit clause would not have precluded the defendant's conviction. State v. Langlands, 276 Ga. 721, 583 S.E.2d 18 (2003).

Court of appeals erred in ruling that a physician's claims that a limited liability company (LLC) violated the Fair Business Practices Act (FBPA), O.C.G.A. § 10-1-399(b), were not barred by res judicata because the physician was barred by a Texas judgment from filing an FBPA claim against the LLC in Georgia, and a Georgia court could not make its own determination regarding whether the forum selection clause in the parties' agreement precluded the filing of an FBPA claim in Georgia; there was no public policy exception to the Full Faith and Credit Clause, and the Texas judgment went to the merits of, and adversely controlled, the physician's claim that the forum selection clause was inapplicable to an FBPA claim. Amerireach.com, LLC v. Walker, 290 Ga. 261, 719 S.E.2d 489 (2011).

Cited in Potter v. Potter, 40 Ga. App. 324, 149 S.E. 579 (1929); O'Malley v. Wilson, 182 Ga. 97, 185 S.E. 109 (1936); John Hancock Mut. Life Ins. Co. v. Yates, 184 Ga. 42, 190 S.E. 560 (1937); Fidelity-Phenix Fire Ins. Co. v. Cortez Cigar Co., 92 F.2d 882 (5th Cir. 1937); Foremost Dairy Prod., Inc. v. Sawyer, 185 Ga. 702, 196 S.E. 436 (1938); Drake v. Drake, 187 Ga. 423, 1 S.E.2d 573 (1939); Smith v. Globe Indem. Co., 65 Ga. App. 838, 16 S.E.2d 601 (1941); McAlhany v. Allen, 195 Ga. 150, 23 S.E.2d 676 (1942); Coulborn v. Joseph, 195 Ga. 723, 25 S.E.2d 576 (1943); Sanders v. Sanford, 138 F.2d 415 (5th Cir. 1943); Tademy v. Scott, 68 F. Supp. 556 (N.D. Ga. 1945); Jarrard v. Southeastern Shipbuilding Corp., 163 F.2d 960 (5th Cir. 1947); Graves v. Carter, 207 Ga. 308, 61 S.E.2d 282 (1950); Richards v. Richards, 85 Ga. App. 605, 69 S.E.2d 911 (1952); Hedquist v. Gottke, 209 Ga. 681, 75 S.E.2d 18 (1953); Blood v. Earnest, 217 Ga. 642, 123 S.E.2d 913 (1962); Watkins v. Conway, 221 Ga. 374, 144 S.E.2d 721 (1965); Funderburg v. Wold, 117 Ga. App. 638, 161 S.E.2d 376 (1968); Richardson v. Strickland, 225 Ga. 319, 168 S.E.2d 146 (1969); Connell v. Connell, 119 Ga. App. 485, 167 S.E.2d 686 (1969); Leathers v. Klebold, 227 Ga. 683, 182 S.E.2d 423 (1971); Showalter v. Sandlin, 229 Ga. 405, 191 S.E.2d 828 (1972); Mahler v. Paquin, 142 Ga. App. 582, 236 S.E.2d 512 (1977); Kronitz v. Fifth Ave. Dance Studio, Inc., 242 Ga. 398, 249 S.E.2d 80 (1978); Bailey v. London Marina, Inc., 151 Ga. App. 73, 258 S.E.2d 738 (1979); FDIC v. Windland Co., 245 Ga. 194, 264 S.E.2d 11 (1980); Hayes v. Hayes, 248 Ga. 526, 283 S.E.2d 875 (1981); City of Alma v. Benham, 170 Ga. App. 143, 316 S.E.2d 477 (1984); Wilson v. Mills, 172 Ga. App. 328, 323 S.E.2d 251 (1984); Park v. Bailey, 329 Ga. App. 569, 765 S.E.2d 721 (2014).

Jurisdiction over members of class required for recognition of foreign judgment affecting them.

- As a condition precedent for the application of the full faith and credit provision of the United States Constitution to the members of a class who may be affected by the judicial proceedings of another state, it must appear that such court had jurisdiction to bind the members of the class wherever located. Eminent Household of Columbian Woodmen v. Bryant, 62 Ga. App. 167, 8 S.E.2d 438 (1940).

Judgment of foreign court having jurisdiction controlling in other states.

- This section compels that controversies be stilled so that if a state court has jurisdiction of the parties and subject matter, its judgment controls in other states to the same extent as it does in the state where rendered. Riley v. New York Trust Co., 315 U.S. 343, 62 S. Ct. 608, 86 L. Ed. 885 (1942).

Presumption favoring jurisdiction conclusive absent adverse evidence in record.

- According to the common-law rule, adhered to at the present time in most states, the presumption in favor of the jurisdiction of a court of general jurisdiction is conclusive, and its judgment cannot be collaterally attacked if no want of jurisdiction is apparent of record. Creaden v. Krogh, 75 Ga. App. 675, 44 S.E.2d 136 (1947).

Decree partially invalid for want of jurisdiction.

- A consent decree of a court of another state, which, in part, seeks to transfer title to realty in this state that had previously been set aside to a widowed spouse and minor children as a year's support, shows upon its face that, insofar as transferring title to realty, the court was without jurisdiction of the subject matter; and, accordingly, that part of the decree is not such a judgment as comes within the full faith and credit clause of the Constitution. King v. King, 203 Ga. 811, 48 S.E.2d 465 (1948).

For purpose of acquiring in personam jurisdiction in Georgia, the term "doing business" means engaging for profit in some practice either repeatedly or possibly with the intention that the practice be repeated and does not include the making of one contract with a nonresident. Allied Fin. Co. v. Prosser, 103 Ga. App. 538, 119 S.E.2d 813 (1961).

U.S. Const. art. IV, sec. I has no application if the foreign judgment shows on its face that there was no jurisdiction of the person of the defendant, and thus shows a violation of due process. Greenfield v. Chronicle Printing Co., 107 Ga. App. 442, 130 S.E.2d 526 (1963).

Collateral attack on decree if foreign court record purports to show jurisdiction.

- A decree might be collaterally attacked by proof that the court which rendered it has no jurisdiction of the parties or cause of action, even though the record of the proceedings in the foreign court purports to show jurisdiction. Logan v. Nunnelly, 128 Ga. App. 43, 195 S.E.2d 659 (1973).

Burden of proof on party asserting lack of jurisdiction.

- The burden is upon the party asserting the invalidity of an out-of-state decree to show that it is not binding, and the jurisdiction of the out-of-state court is to be presumed until it is proved by evidence or the record itself. Logan v. Nunnelly, 128 Ga. App. 43, 195 S.E.2d 659 (1973).

Litigation of issue of jurisdiction of foreign court binding on other court.

- In collateral attack on a judgment of another court respecting jurisdiction over the defendant, once it is shown that such issue was fully litigated in the original court, the judgment is binding under the full faith and credit clause. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Collateral attacks on foreign judgments for want of jurisdiction.

- The broad and general statement that a collateral attack upon a foreign judgment for want of jurisdiction is not barred by the full faith and credit clause of the Constitution is subject to exceptions. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

If a party is personally served that party is subject to in personam jurisdiction of courts of a foreign state and cannot collaterally attack a judgment of such court. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

If the question of jurisdiction is raised in foreign court and decided adversely to a party, that party may not collaterally attack this determination. If the record reveals that the personal jurisdiction issue was raised by a defendant and decided adversely to the defendant by a court of otherwise competent jurisdiction, the judgment of that court is conclusive, is res judicata, and may not be collaterally attacked. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

A judgment of a foreign court will be enforced by the courts of this state. However, that judgment may be collaterally attacked where the foreign court lacked jurisdiction of the person or subject matter. Yet, if the defendant fails to appear at trial but makes a post-judgment appearance and moves to set aside the judgment, the issues raised and decided adversely to the defendant in the post-judgment hearing by a foreign court of otherwise competent jurisdiction are conclusive, res judicata, and may not be collaterally attacked in the Georgia court. International Sys. v. Bladen County, 168 Ga. App. 316, 308 S.E.2d 679 (1983).

Presumption of jurisdiction where merely dependent on existence of facts.

- If the question as to the jurisdiction of the court depends merely upon the existence or nonexistence of a fact, and the judgment is otherwise regular, and the court otherwise a court of competent jurisdiction, it is to be presumed that the court found facts to exist such as warranted its assuming jurisdiction, and such finding of fact cannot be collaterally attacked. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

On facts, jurisdictional issue not subject to collateral attack.

- Because a defendant made a special appearance to contest personal jurisdiction, was fully heard, was overruled as to this objection and took no further part in the case or sought review of the adverse ruling, the judgment entered against the party on the merits was res judicata with regard to the jurisdictional issue and not subject to collateral attack on that ground when sued upon in another state. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

Effect of foreign statute conferring continuing jurisdiction over minor upon court granting divorce on nonresident.

- The Indiana statute that confers continuing jurisdiction over the minor child upon the court that granted the divorce decree cannot confer jurisdiction on a trial court in Indiana over an out-of-state resident who does not consent to or become subject in some way to the jurisdiction of the Indiana court. Schowe v. Amster, 236 Ga. 720, 225 S.E.2d 289 (1976).

Foreign adjudications of jurisdictional issues res judicata in other courts.

- The doctrine of res judicata must be applied to questions of jurisdiction in cases arising in state courts involving the application of the full faith and credit clause where, under the law of the state in which the original judgment was rendered, such adjudications are not susceptible to collateral attack. Kingdon v. Foster, 238 Ga. 37, 230 S.E.2d 855 (1976), cert. denied, 431 U.S. 916, 97 S. Ct. 2179, 53 L. Ed. 2d 226 (1977).

Personal jurisdiction of foreign court is necessary before judgment from foreign jurisdiction will be given full faith and credit. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Effect of section on attacking jurisdiction of foreign courts.

- Neither the full faith and credit clause of the United States Constitution nor any Act of Congress passed in pursuance thereof, forbids or prevents an inquiry into the jurisdiction of the court by which the judgment offered in evidence in another state was rendered. Masters v. ESR Corp., 150 Ga. App. 658, 258 S.E.2d 224 (1979).

Judgment of foreign court lacking personal jurisdiction is not entitled to full faith and credit in the State of Georgia, inasmuch as a judgment of any court that lacks jurisdiction is void. Capital Bank v. Levy, 151 Ga. App. 819, 261 S.E.2d 722 (1979).

The Mississippi rule that a surety is bound to a judgment against its principal is entitled to no extraterritorial effect in a suit against the surety in Georgia, where the surety was not a party or privy to the Mississippi litigation involving the principal. Rouse Constr., Inc. v. Transamerica Ins. Co., 750 F.2d 1492 (11th Cir. 1985).

Sole basis for precluding collateral attack on jurisdiction of foreign court.

- A collateral attack upon a petition to domesticate a foreign (sister state) judgment that it was based on lack of personal jurisdiction is precluded in this state only if the defendant has appeared in the foreign court and has thus had an opportunity to litigate the issue. Maxwell v. Columbia Realty Venture, 155 Ga. App. 289, 270 S.E.2d 704 (1980).

In a suit brought to domesticate a Pennsylvania judgment for back taxes where the record showed that the defendant appeared, by and through counsel, and contested the Pennsylvania suit on its merits, an attack on the jurisdiction of the Pennsylvania court was without merit. Hopkins v. City of Philadelphia, 155 Ga. App. 534, 271 S.E.2d 672 (1980).

Personal jurisdiction in revival action.

- Because a defendant had the requisite minimum contacts with the forum state for that state to exercise personal jurisdiction over the defendant during the original litigation, those same contacts were sufficient to provide personal jurisdiction to the trial court for any revival action concerning the judgment entered in the course of the original litigation. Kaylor v. Turner, 210 Ga. App. 2, 435 S.E.2d 233 (1993).

In general.

- A class of cases in which recognition of the law of the situs of the contract has been required comprises cases in which a right validly acquired under the law of the other state is set up by way of defense to an action in the forum, the law of which is opposed or contrary to the defensive matter. In such cases the requirement of the full faith and credit provisions is aided by the due process and contract provisions of the Constitution, to bring about recognition of foreign law, since enforcing the contract or other right stripped of the defensive provision valid under the applicable law would be making a new and different contract or creating a new right, and this would amount to a taking of property without due process of law, or in violation of the contract. Terry v. Mays, 161 Ga. App. 328, 291 S.E.2d 44 (1982).

Validity, form, and effect of contracts are to be determined generally by law of place where made. John Hancock Mut. Life Ins. Co. v. Yates, 299 U.S. 178, 57 S. Ct. 129, 81 L. Ed. 106 (1936).

Effect on section of prosecution for possession of whiskey bearing revenue stamps from sister state only.

- The offense of possessing whiskey in Georgia not bearing the required revenue stamps is not mitigated, nor is the prosecution defeated, by the fact that the whiskey bears the revenue stamps of another state; such prosecution is not a violation of the interstate commerce clause of the Constitution of the United States or of U.S. Const., art. IV, sec. I. Herbert v. State, 60 Ga. App. 633, 4 S.E.2d 843 (1939).

Rights of contractual parties governed by statutes and decisions of state where contract made.

- The rights of the parties to a contract made and to be performed in another state are controlled not only by that state's pertinent statutes but by the decisions of its appellate courts construing and applying those statutes. Motz v. Alropa Corp., 192 Ga. 176, 15 S.E.2d 237 (1941).

Nonresident policyholder subject to liabilities imposed by laws of insurance corporation's domicile.

- If a resident of this state accepts a policy of insurance issued by a mutual insurance corporation of another state, by the terms of which the insured becomes a member of the corporation, the insured thereby is subject to the liabilities imposed upon its members by the laws of the domiciliary state. Gaston v. Keehn, 69 Ga. App. 500, 26 S.E.2d 107 (1943).

Giving effect to foreign statute absent compliance by plaintiff with domestic statute.

- Because plaintiff knew at time of sale of automobiles to Georgia dealer that they were to be brought into Georgia, and failed to have executed either a title retention contract or a bill of sale to secure debt and to record such an instrument, either of which, under Georgia law, would have been an appropriate step to protect his interest in the automobiles, the full faith and credit clause of the United States Constitution did not require, under the circumstances, that Georgia courts give extraterritorial effect to the Florida automobile title registration law. Cook Motor Co. v. Richardson, 103 Ga. App. 129, 118 S.E.2d 502 (1961).

Extraterritorial effect of state's exclusive statutory remedy for injuries to its residents outside state.

- A state can fix one exclusive remedy for personal injuries involving its residents wherever the accident happens and the full faith and credit clause requires the other states to refuse to enforce any inconsistent remedy. Crider v. Zurich Ins. Co., 380 U.S. 39, 85 S. Ct. 769, 13 L. Ed. 2d 641 (1965).

Burden of showing superiority of foreign state's interest over that of forum on party so asserting.

- Every state is prima facie entitled to enforce in its own courts its own statutes, lawfully enacted. One who challenges that right, because of the force given to a conflicting statute of another state by the full faith and credit clause or for any other reason, assumes the burden of showing, upon some rational basis, that of the conflicting interests involved those of the foreign state are superior to those of the forum. Security Ins. Group v. Plank, 133 Ga. App. 815, 212 S.E.2d 471 (1975).

Application of forum's statute absent proof of foreign statute.

- In a case in which the plaintiffs sought to domesticate action in Maryland for debt against a partnership in which a Georgia resident was served by allegedly mailing to the Georgia resident a copy of the pleadings in the State of Georgia, the law of Georgia as to validity of service would apply in the absence of any proof of the Maryland statute. Maxwell v. Columbia Realty Venture, 155 Ga. App. 289, 270 S.E.2d 704 (1980).

Effect given to judgments of sister state to same extent as given in sister state.

- Action on a foreign judgment, being properly authenticated and rendered by a court of a sister state, is to be given the same full faith and credit in the courts of this state as it would have in the courts of the state where it was rendered. Albert v. Albert, 86 Ga. App. 560, 71 S.E.2d 904 (1952).

Full faith and credit clause requires that judgment in one state must be given such full effect in another state as it is given by the law and usage of the state of its origin. Peeples v. Peeples, 103 Ga. App. 462, 119 S.E.2d 710 (1961).

Foreign judgments given such effect as accorded in rendering state.

- It is fundamental that under the full faith and credit clause the courts of this state are required to give only such effect to a judgment of a sister state as it would have in that state. Jackson v. Jackson, 231 Ga. 751, 204 S.E.2d 297 (1974).

Judgments of courts of one state must be given the same faith and credit in another state as they have by law or usage in the courts of the state rendering them. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff 'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Full faith and credit accorded judgments based on constitutional laws of sister states.

- Full faith and credit will be accorded by Georgia to judgments rendered in sister states based upon the constitutional laws of those states. Allied Fin. Co. v. Prosser, 103 Ga. App. 538, 119 S.E.2d 813 (1961).

Recognition of foreign judgment under review by supreme court of state rendering judgment.

- This section requires courts of Georgia to give full faith and credit to a judgment of another state's court even where it is shown that the supreme court of that state has such judgment under review. Ferster v. Ferster, 220 Ga. 319, 138 S.E.2d 674 (1964).

Under U.S. Const., art. IV, sec. I, judgment of foreign court will be enforced by courts of this state. That judgment, however, may be collaterally attacked where the foreign court lacked jurisdiction of the person or subject matter or where the judgment was procured by fraud. Gordon v. Gordon, 237 Ga. 171, 227 S.E.2d 53 (1976).

Foreign judgments entitled to full faith and credit.

- Under the full faith and credit clause, a judgment of a foreign court will be enforced by the courts of this state unless it is shown that the foreign court lacked jurisdiction of the person or subject matter or that the judgment was procured by fraud. Dropkin v. Dropkin, 237 Ga. 768, 229 S.E.2d 621 (1976); Veazey v. Veazey, 246 Ga. 376, 271 S.E.2d 449 (1980); Paris v. Cooper, 158 Ga. App. 212, 279 S.E.2d 507 (1981).

Courts of Georgia are required by U.S. Const., art. IV, sec. I to give full faith and credit to judgments of sister states. A judgment in one state is conclusive upon the merits in every other state, but only if the court of the first state had jurisdiction. Haire v. Eide, 150 Ga. App. 52, 256 S.E.2d 658 (1979).

Proper foreign judgments entitled to full faith and credit.

- The judgment of a court of one state, when sued on, pleaded, or introduced in evidence in another state, is entitled to receive the same full faith, credit, and respect that is accorded to it in the state where rendered. If it is valid and conclusive there, it is so in all other states. Masters v. ESR Corp., 150 Ga. App. 658, 258 S.E.2d 224 (1979).

Foreign judgment properly proved entitled to full faith and credit.

- The full faith and credit clause of the United States Constitution requires the courts of this state to give effect to a judgment granted in a sister state when the same is properly proved in a proceeding in which it may be relevant. Melnick v. Bank of Highwood, 151 Ga. App. 261, 259 S.E.2d 667 (1979).

Judgment rendered by competent court of another state is conclusive on merits in courts of this state when made the basis of an action or defense, and the merits cannot be reinvestigated. A foreign judgment is conclusive as to all matters which were decided or could have been heard at the time of the obtaining of the foreign judgment. Melnick v. Bank of Highwood, 151 Ga. App. 261, 259 S.E.2d 667 (1979).

Foreign judgments given same effect as accorded in rendering state.

- Under the full faith and credit clause, the Georgia courts are required to give only such effect to a foreign judgment as it would have in the foreign state. Capital Bank v. Levy, 151 Ga. App. 819, 261 S.E.2d 722 (1979).

Foreign judgments entitled to full faith and credit conclusive on merits in forum.

- Lawfully obtained judgments of the court of one state, when sued on or pleaded or introduced in evidence in another state, are entitled to receive the same full faith, credit, and respect that they are accorded in the state where rendered, and the foreign judgment is conclusive as to all matters which were decided or could have been heard at the time of the obtaining of the foreign judgment. Trammell v. Burke, 154 Ga. App. 366, 268 S.E.2d 417 (1980).

Prerequisites of foreign judgments entitled to full faith and credit.

- If a judgment sued on is complete and regular upon its face and contains recitals as to the jurisdictional facts, it is entitled to full faith and credit. Lowther v. Mathers, 147 Ga. App. 82, 248 S.E.2d 161 (1978).

U.S. Const., art. IV, sec. I makes the valid in personam judgment of one state enforceable in all other states. Williamson v. Williamson, 247 Ga. 260, 275 S.E.2d 42, cert. denied, 454 U.S. 1097, 102 S. Ct. 669, 70 L. Ed. 2d 638 (1981).

Recognition of judgment based on fraud.

- There is no obligation on the part of one state to recognize a judgment rendered in another that originated in a fraudulent intention maintained and carried out on the same basis. Cochran v. Cochran, 173 Ga. 856, 162 S.E. 99 (1931).

Decree in court of domicile of corporation is evidence in every other state that corporation is insolvent, and that a proper case exists in that state for the appointment of a receiver, and it is to be respected accordingly in obedience to the full faith and credit provision of the United States Constitution; but it is for the court to which an application for appointment of a receiver is made to decide whether the proper administration of the assets requires the appointment of a receiver. Ordinarily, in comity to the proceeding of another court of coordinate jurisdiction, it will appoint an ancillary receiver and assume administration in aid of the primary receiver. Isaac Silver & Bros. Co. v. Kalmon, 175 Ga. 244, 165 S.E. 434 (1932).

Satisfied judgment against garnishee recognized as payment of original debt in action by original creditor.

- A judgment against a garnishee, properly obtained according to the law of the state and paid, must, under the full faith and credit clause of the federal Constitution, be recognized as a payment of the original debt by the courts of another state in an action brought against the garnishee by the original creditor. H.J. Heinz Co. v. Fortson, 61 Ga. App. 52, 6 S.E.2d 594 (1939).

Foreign judgment having effect of former adjudication in matters pending in forum state.

- Under the full faith and credit clause of the Constitution, a judgment of a court of competent jurisdiction in Tennessee, if properly proved, may have the effect of former adjudication in matters pending in the courts of this state. Roadway Express, Inc. v. McBroom, 61 Ga. App. 223, 6 S.E.2d 460 (1939).

Proper foreign judgments regarding contracts of fraternal societies binding on nonresident members.

- Decisions of the United States Supreme Court affecting fraternal benefit societies have universally held that a decision by a court having jurisdiction in the state where the society or company is incorporated respecting matters of interpretation of its charter or contracts is binding on members similarly situated in other states. Eminent Household of Columbian Woodmen v. Bryant, 62 Ga. App. 167, 8 S.E.2d 438 (1940).

Effect of judgment assessing corporation members on nonresident policyholder.

- If a court of the domiciliary state of an insolvent mutual corporation having jurisdiction thereof proceeds according to the applicable statutes to determine the necessity for and the amount of an assessment against its members, such proceedings are conclusive as to the necessity for and the amount of the assessment, when asserted against a nonresident policyholder who by the express terms of his policy became a member of the corporation, although he was not made a party to said proceedings. An assessment levied by court order upon members of such a corporation, in conformity with the statutes of the state of its organization, against a nonresident member who is not a party to the proceedings, involves no want of due process and is entitled to full faith and credit so far as the necessity and amount of the assessment are concerned. Gaston v. Keehn, 69 Ga. App. 500, 26 S.E.2d 107 (1943).

Validity of a judgment when collaterally attacked must be tried by an inspection of the judgment roll alone, and no other or further evidence on the subject is admissible, not even evidence that no notice had been given. Creaden v. Krogh, 75 Ga. App. 675, 44 S.E.2d 136 (1947).

Validity of foreign judgment by confession of attorney in court.

- Full faith and credit is given by Georgia courts to valid judgments from other states, where such judgments do not contravene Georgia laws. A valid judgment by confession of an attorney in a court is not such a judgment as would contravene Code 1933, Ch. 110-6. Cocke v. Truslow, 91 Ga. App. 645, 86 S.E.2d 686 (1955).

Recitation in final order that service was perfected imports absolute verity until properly controverted in the Georgia court by pleadings raising the issue that such service was not legal service and that the judgment rendered on such service would not be entitled to credit according to the law or usage of Florida. Peeples v. Peeples, 103 Ga. App. 462, 119 S.E.2d 710 (1961).

Effect of foreign decree on one not party to original proceeding where evidence shows it to be nullity.

- If the evidence of one relying upon a foreign decree conclusively shows that such decree is a nullity, the courts of this state are not required to give it full faith and credit and a person not a party to such divorce proceeding whose rights are materially and adversely affected by it may collaterally attack its validity in the courts of this state. Cole v. Cole, 221 Ga. 171, 143 S.E.2d 637 (1965).

Proper foreign judgment conclusive on its merits in forum.

- A litigant in the courts of this state relying on the judgment of a sister state in support of or in defense to an action is in general entitled to have such a judgment accorded the same full faith and credit, and no more, as it would receive in the state where rendered, and such a judgment by a court of competent jurisdiction of another state is to this extent conclusive on its merits in the courts of this state. Kelly v. Kelly, 115 Ga. App. 700, 155 S.E.2d 732 (1967).

Collateral attack of judgment of foreign court having jurisdiction on ground of fraud.

- A judgment of a court of a foreign state having jurisdiction of the subject matter and the parties cannot be collaterally attacked in the courts of this state on the ground of fraud. Johnson v. Johnson, 115 Ga. App. 749, 156 S.E.2d 186 (1967).

Valid judgment cannot be attacked collaterally until set aside or reversed. Costello v. Costello, 230 Ga. 40, 195 S.E.2d 408 (1973).

Proper foreign judgment offered as evidence in forum court unimpeachable for fraud.

- A judgment rendered by a court having jurisdiction of the subject matter, and apparently legal on its face, when offered as evidence in a cause pending in this state, cannot be collaterally impeached for fraud. Logan v. Nunnelly, 128 Ga. App. 43, 195 S.E.2d 659 (1973).

Nonfinal foreign judgments not entitled to full faith and credit.

- If an action is based upon a foreign judgment which is not final in the state where rendered, such judgment is not entitled to recognition under the full faith and credit doctrine. Ryle v. Ryle, 130 Ga. App. 680, 204 S.E.2d 339 (1974).

Only final judgments accorded full faith and credit.

- A judgment of a state court, in order to be given full faith and credit in another jurisdiction, must be a final judgment adjudicating the litigation in a conclusive manner. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Recognition of foreign judgments subject to appeal.

- The fact that a foreign judgment is subject to an appeal does not render it interlocutory within the meaning of the rule denying full faith and credit to interlocutory judgments; the full faith and credit clause of the United States Constitution applies as soon as a judgment is enforceable, and not merely after the time to appeal has elapsed. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Judgment from which appeal has been taken without supersedeas is final judgment entitled to be accorded full faith and credit, even though the appeal is still pending in the court of the original jurisdiction. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Effect of collateral attack for fraud on recognition of foreign judgment.

- Full faith and credit does not have to be accorded a judgment where the collateral attack is based on its procurement through fraud. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Impeachment of a foreign judgment is limited to existence of fraud that is extrinsic in its nature, that is, fraud preventing one from having a real contest of the action based on conduct or activities outside of the court proceedings themselves. Fraudulent acts that pertain to an issue involved in the original action which was litigated or could have been litigated therein may not be relitigated in another state's courts. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975).

Foreign judgment entitled to full faith and credit where issues fully and fairly litigated in original court.

- A judgment is entitled to full faith and credit, even as to questions of jurisdiction, when the second court's inquiry discloses that those questions have been fully and fairly litigated and finally decided in the court which rendered the original judgment. Fidelity Std. Life Ins. Co. v. First Nat'l Bank & Trust Co., 382 F. Supp. 956 (S.D. Ga. 1974), aff'd, 510 F.2d 272 (5th Cir.), cert. denied, 423 U.S. 864, 96 S. Ct. 125, 46 L. Ed. 2d 94 (1975); Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

When party appears and defends, judgment of court, regular upon its face, may not be attacked in the courts of this state. Green Acres Disct., Inc. v. Freid & Appell, Inc., 135 Ga. App. 816, 219 S.E.2d 39 (1975).

Effect of conflict of laws on according full faith and credit to foreign judgment.

- Even if the statutory law of this state is different from that of the sister state, and even if this would prevent recovery (conceding arguendo that there is such a difference), the forum state (Georgia) must give full faith and credit to that judgment rendered by the sister state. Colodny v. Krause, 136 Ga. App. 379, 221 S.E.2d 239 (1975).

Judgment in corporate liquidation proceedings.

- Because the Delaware Chancery Court, pursuant to applicable statute, had power to wind up the affairs of a corporation that is a creature of the laws of that state, and, as part of that winding up, state court disposed of property of such company although majority stockholder was not named as party in the liquidation proceeding but was merely notified, the United States District Court properly gave full faith and credit to the state court proceeding by granting summary judgment in favor of the state court's holding, thus, effectively causing such proceeding to be enforceable against the majority stockholder. CMS Indus., Inc. v. L.P.S. Int'l, Ltd., 643 F.2d 289 (5th Cir. 1981).

Judgment rendered by court of another state is conclusive on merits in courts of this state when made the basis of an action and the merits cannot be reinvestigated. Flagship Bldrs., Inc. v. Sentinel Star Co., 143 Ga. App. 624, 239 S.E.2d 235 (1977).

Foreign judgment conclusive on merits only if rendering court had jurisdiction.

- A judgment in one state is conclusive upon the merits in every other state, but only if the court of the first state had power to pass on the merits - had jurisdiction, that is, to render the judgment. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Enforcement of foreign judgments subject to collateral attack.

- A judgment of a foreign court will be enforced by the courts of Georgia. That judgment, however, may be collaterally attacked where the foreign court lacked jurisdiction of the person or subject matter. Collins v. Peacock, 147 Ga. App. 424, 249 S.E.2d 142 (1978).

Proper foreign judgment not subject to collateral attack.

- A judgment rendered by a court of competent jurisdiction of a sister state, properly authenticated, is conclusive on the merits in the courts of this state when made the basis of action and the merits cannot be reinvestigated, i.e., such a judgment is not subject to collateral attack. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Georgia is not required by the full faith and credit clause to recognize nonfinal decrees. Blue v. Blue, 243 Ga. 22, 252 S.E.2d 452 (1979).

Only final foreign judgments entitled to full faith and credit.

- To entitle the judgment of the court of a sister state to full faith and credit and to endow it with conclusive effect, the judgment must be final. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Law of state of rendition determines whether judgment is final and, if not, what issues remain subject to further determination. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Nature of final judgments.

- Final judgments are such as at once put an end to the action, by declaring that the plaintiff has either entitled himself, or has not, to recover the remedy he sues for. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Allowing actions based on unsatisfied final foreign judgments.

- Under the full faith and credit clause, Georgia must recognize the final and unmodifiable judgments of sister states, and permit actions for amounts due and unpaid thereunder up until the time of action. Williamson v. Williamson, 247 Ga. 260, 275 S.E.2d 42, cert. denied, 454 U.S. 1097, 102 S. Ct. 669, 70 L. Ed. 2d 638 (1981).

Modification of foreign decree modifiable by rendering state.

- Modification of a sister state decree does not offend the full faith and credit clause so long as the decree is modifiable by the rendering state, because the forum state has at least as much leeway to disregard the judgment, to qualify it, or to depart from it as does the state where it was rendered. Blue v. Blue, 243 Ga. 22, 252 S.E.2d 452 (1979).

Foreign judgment void as against public policy of forum entitled to full faith and credit.

- That the North Carolina consent judgment contains a clause making it void as against the public policy of this state does not change the rule that local policy considerations must give way to this constitutional provision. Cannon v. Cannon, 244 Ga. 299, 260 S.E.2d 19 (1979).

Foreign order void as violating Georgia public policy.

- Michigan order, by facially prohibiting consultant from testifying as to matters outside the scope of any privilege, violated Georgia public policy; therefore, the full faith and credit clause did not require the federal district court in Georgia to give full effect to the Michigan court order. Williams v. GMC, 147 F.R.D. 270 (S.D. Ga. 1993).

Interpretation of foreign decree by forum enforcing it.

- While a foreign decree may not be altered or modified by the courts of this state, it may be interpreted and effect given to its legal intendment by a court of this state in which an action is brought to enforce such decree. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Domestication of foreign judgment separate issue from enforcement of judgment.

- Domestication in this state of a foreign judgment is a separate issue from the extent to which enforcement of that domesticable judgment will be authorized. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Foreign judgments must be domesticated.

- Because a foreign judgment cannot be enforced until it is domesticated, a Georgia judgment had priority over an earlier obtained, but later domesticated, foreign judgment against the same debtor. NationsBank v. Gibbons, 226 Ga. App. 610, 487 S.E.2d 417 (1997).

Payment is complete defense to enforcement of foreign judgment entitled to full faith and credit and domestication in this state, and the defendant may plead partial satisfaction or any other affirmative defense to the enforcement sought in an action on the domesticable judgment. Sun First Nat'l Bank v. Gainesville 75, Ltd., 155 Ga. App. 70, 270 S.E.2d 293 (1980).

Workers' compensation award decision.

- The full faith and credit clause does not require that the decision in another state that a person is no longer entitled to benefits is a bar to an award under Georgia law when jurisdiction is invoked under O.C.G.A. § 34-9-242. Roadway Express, Inc. v. Warren, 163 Ga. App. 759, 295 S.E.2d 743 (1982), cert. dismissed as improvidently granted, 464 U.S. 988, 104 S. Ct. 476, 78 L. Ed. 2d 675 (1983).

Discharge or payment of judgment is defense to execution of a foreign judgment. Armstrong v. Strand, 167 Ga. App. 723, 307 S.E.2d 528 (1983).

Foreign divorce decree unentitled to recognition absent personal service on wife.

- A Nevada decree, rendered without personal service of process on a spouse and therefore without personal jurisdiction over the spouse, was not entitled to enforcement in this state by virtue of the full faith and credit clause of the federal Constitution. Cochran v. Cochran, 173 Ga. 856, 162 S.E. 99 (1931).

Foreign alimony decree enforceable as to unpaid payments.

- A decree for alimony from a sister state, providing for future monthly payments, is such a decree as is enforceable in this state under the full faith and credit clause of the Constitution of the United States as to such payments as have become due and remain unpaid at the time of the rendition of the judgment in this state, although the foreign court retains jurisdiction for the purpose of modifying the judgment. Roberts v. Roberts, 174 Ga. 645, 163 S.E. 735 (1932); Lawrence v. Lawrence, 196 Ga. 204, 26 S.E.2d 283 (1943); McLendon v. McLendon, 66 Ga. App. 156, 17 S.E.2d 252 (1941), later appeal, 70 Ga. App. 664, 29 S.E.2d 97 (1944); Johnson v. Johnson, 115 Ga. App. 749, 156 S.E.2d 186 (1967).

On facts, foreign divorce decree collaterally attackable for fraud.

- A decree of divorce rendered in the State of Alabama on a bill of complaint by the husband alleging himself to be a bona fide resident of that state and the respondent to be a nonresident of the state, which was based upon appearance and pleading alone by the respondent as waiver of service and submission to the jurisdiction, may be collaterally attacked for fraud in its procurement. Durden v. Durden, 184 Ga. 421, 191 S.E. 455 (1937).

Foreign decree obtained on service by publication not entitled to full faith and credit.

- Where a decree of divorce is obtained in another state on service by publication and there is no appearance or response by the defendant, such decree is not binding on the courts of this state under the full faith and credit clause of the United States Constitution. Barnett v. Barnett, 191 Ga. 501, 13 S.E.2d 19 (1941).

On facts, foreign decree obtained on service by publication collaterally attackable for want of jurisdiction.

- Because only service upon the wife in the husband's suit for divorce in foreign state was by publication, and the wife made no appearance and contested none of the allegations of that suit, the wife had a right to collaterally attack the foreign decree upon the grounds that the court was without jurisdiction because the husband had not been a bona fide resident of the foreign state for a period of one year as required by the laws of that state to give the court jurisdiction and that the husband's representation to the court that the husband had been such a bona fide resident was false and fraudulent. Marchman v. Marchman, 198 Ga. 739, 32 S.E.2d 790 (1945).

Foreign decree obtained without personal service on nonresident subject to collateral attack.

- The full faith and credit clause of the Constitution of the United States has no application to a decree of divorce where the defendant in the divorce action was a nonresident, made no appearance, and the only service had was by publication; such a divorce decree is subject to a collateral attack showing that the court rendering the same was without jurisdiction or that the decree was procured by the perpetration of a fraud upon the court. Marchman v. Marchman, 198 Ga. 739, 32 S.E.2d 790 (1945).

Procedure for enforcement of foreign alimony decree.

- An order and decree for alimony from another state, providing for future weekly payments, is such a decree as is enforceable in Georgia under the full faith and credit clause of the Constitution of the United States as to such payments as have become due and remain unpaid, when an action is brought in a court of competent jurisdiction in Georgia on a judgment entered in another state for the total of the unpaid payments which have accrued to the date of the judgment rendered in such other state. Creaden v. Krogh, 75 Ga. App. 675, 44 S.E.2d 136 (1947).

Jurisdiction of foreign court rendering decree prima facie presumed valid.

- Because the record of the proceedings and decree in the Nevada court, which the defendant offered in evidence, shows on its face that the court had jurisdiction of the plaintiff and the defendant had his residence in Nevada, under the full faith and credit clause of the federal Constitution, the trial court was under a duty to accord prima facie validity to the Nevada decree; and, upon the admission of the judgment and record in that case, the burden was upon the plaintiff, if the plaintiff would escape the operation of the decree, to show that it was not binding upon the plaintiff, and such jurisdiction of the Nevada court over the cause of action and the parties is to be presumed until disproved by evidence or by the record itself. Patterson v. Patterson, 208 Ga. 7, 64 S.E.2d 441 (1951).

Presumption rebuttable by evidence showing domicile outside foreign decree forum.

- The presumption of validity of a foreign divorce decree is rebuttable by evidence of the attacking party showing a lack of domicile of the plaintiff in the foreign divorce forum; and, if the evidence shows that the plaintiff was not a bona fide resident of the foreign state at the time the divorce action was instituted, the court may decline to give full faith and credit to the decree, notwithstanding the finding of the foreign decree that he was such a resident. Patterson v. Patterson, 208 Ga. 7, 64 S.E.2d 441 (1951).

Foreign divorce decree showing jurisdiction entitled to recognition in in-state divorce action.

- An amendment to the husband's answer, in an in-state divorce action by the wife, setting up a final divorce decree from a court of foreign state, which decree showed on its face that such court had jurisdiction over the parties and the cause of action for a divorce, is prima facie entitled to respect by the courts of this state under the full faith and credit clause of the federal Constitution. Cherry v. Cherry, 208 Ga. 213, 65 S.E.2d 805 (1951).

Full faith and credit clause places Georgia courts under duty to accord prima facia validity to Texas divorce decree. Meeks v. Meeks, 209 Ga. 588, 74 S.E.2d 861 (1953).

Effect of foreign divorce decree on temporary alimony order.

- Full faith and credit under the Constitution of the United States does not demand that support and maintenance due the wife under a temporary alimony order of the courts of Georgia cease when a valid divorce is granted between the parties in another state. Meeks v. Meeks, 209 Ga. 588, 74 S.E.2d 861 (1953).

Effect of pending divorce action on divorce decree procured in sister state.

- The mere fact that spouse had a divorce action pending in a court in Georgia at the time he procured a Texas divorce is not sufficient to rebut the prima facia validity of the Texas decree, since whether or not there was an action pending in Georgia for the same cause was not a jurisdictional fact in the cause in Texas. Meeks v. Meeks, 209 Ga. 588, 74 S.E.2d 861 (1953).

Mere production of copy of foreign divorce decree without more insufficient to invalidate it.

- Although it is true that a Texas divorce decree may be collaterally attacked in the courts of Georgia on the grounds of lack of jurisdiction in the Texas court or fraud in the procurement of the decree, and that the Georgia courts may determine those questions for themselves, where the only evidence produced in proceeding by wife to have husband adjudged in contempt for failure to pay temporary alimony was a copy of the husband's Texas divorce decree, and no question regarding the jurisdiction of the Texas court or of fraud in the procurement of the decree is presented, the Constitution of the United States demands that the Texas decree be given full faith and credit. Meeks v. Meeks, 209 Ga. 588, 74 S.E.2d 861 (1953).

Foreign decree obtained on personal service or by appearance of both parties valid.

- If there has been personal service or if the parties both actually appear and participate in the trial by pleading and personal appearance, this court holds that a divorce decree rendered by the courts of another state, under these circumstances, is not subject to collateral attack. Smith v. Smith, 211 Ga. 615, 87 S.E.2d 320 (1955).

Full faith and credit not accorded foreign decree subject to collateral attack.

- If the only service obtained in a divorce action is by publication, when the defendant is a nonresident and does not appear and defend the action and has no actual notice of the pendency of the action, the decree is subject to attack on the ground that the court rendering the decree had no jurisdiction of the parties, or that the decree was obtained by the perpetration of a fraud upon the court rendering the decree, and the full faith and credit clause of the Constitution of the United States and the Act of Congress enacted pursuant thereto, 28 U.S.C. § 1738, have no application under these circumstances. Smith v. Smith, 211 Ga. 615, 87 S.E.2d 320 (1955).

Decree unattackable in rendering state is unattackable in any state.

- If a divorce cannot be attacked for lack of jurisdiction by parties actually before the court or by strangers in the rendering state, the full faith and credit clause forbids an attack by them anywhere in the United States. A state by virtue of U.S. Const., art. IV, sec. I must give full faith and credit to a foreign divorce decree by barring either party to that divorce who has been personally served or who has entered a personal appearance from collaterally attacking the decree, where the decree is not susceptible to such collateral attack in the courts of the state which rendered it. Woody v. Woody, 91 Ga. App. 806, 87 S.E.2d 222 (1955).

Elements essential to foreign divorce decree for full faith and credit.

- The decisions of this court up to this time have uniformly held that the full faith and credit clause of the Constitution of the United States and the Act of Congress enacted in pursuance thereof, 28 U.S.C. § 1738, have no application to a decree of divorce if the defendant in the divorce action was a nonresident, made no appearance, and the only service had was by publication, and that such a divorce decree is subject to a collateral attack showing that the court rendering the same was without jurisdiction or that the petitioner therein procured the decree by the perpetration of a fraud upon the court rendering the same. But if there has been personal service or the defendant appears and defends, a decree of divorce rendered by a court of another state and regular upon its face is not subject to attack in the courts of this state. Wade v. Wade, 213 Ga. 886, 102 S.E.2d 557 (1958).

Foreign alimony decree subject to revocation or modification unenforceable.

- A decree for alimony of a sister state, providing for future monthly payments, which by its own terms is subject to be revoked or modified as to the amount to be paid thereunder by the court rendering such decree, is not enforceable in this state under U.S. Const., art. IV, sec. I or upon principles of comity. Ferster v. Ferster, 219 Ga. 543, 134 S.E.2d 600 (1964).

Effect of foreign divorce on support and maintenance order.

- Full faith and credit under the Constitution of the United States does not demand that support and maintenance due the spouse under an order of the courts of Georgia cease when a valid divorce is granted between the parties in another state. Spadea v. Spadea, 225 Ga. 80, 165 S.E.2d 836 (1969).

Foreign divorce properly proved entitled to full faith and credit.

- U.S. Const., art. IV, sec. I requires the courts of this state to give effect to a divorce granted in a sister state when the same is properly proved in a proceeding in which it may be relevant in this state. Spadea v. Spadea, 225 Ga. 80, 165 S.E.2d 836 (1969).

Foreign divorce decree properly rendered not subject to collateral attack.

- Under U.S. Const., art. IV, sec. I, a divorce decree of a sister state rendered after personal service on the defendant and after the defendant has appeared in person or by attorney and defended the same on the merits, which decree is regular upon its face, is not subject to collateral attack in the courts of this state but must be given full force and effect as if rendered by a court of this state. Joyner v. Joyner, 227 Ga. 545, 181 S.E.2d 842 (1971).

Foreign divorce decree attacked for fraud as bar to alimony action.

- The rule prevailing in this state is that a decree of divorce, obtained by a husband in another state, wherein service is perfected on the wife, a resident of this state, by publication, and in which the plaintiff in such foreign judgment is not in fact a bona fide resident of the state in which the judgment is rendered, can be attacked collaterally for fraud when offered in the courts of this state, as a bar to the wife's action for alimony. Logan v. Nunnelly, 128 Ga. App. 43, 195 S.E.2d 659 (1973).

Ex parte divorce decree valid in other states if one spouse domiciled in forum.

- An ex parte judgment that only grants a divorce is entitled to full faith and credit in other states if one of the spouses was domiciled in the forum that granted the divorce judgment. Whitaker v. Whitaker, 237 Ga. 895, 230 S.E.2d 486 (1976).

Foreign divorce decree unimpeachable in rendering state is unimpeachable in any state.

- If a decree of divorce cannot be attacked on jurisdictional grounds by parties who were actually before the court, or by their privies, or by strangers, in the courts of the state in which the decree was rendered, the full faith and credit clause precludes their attacking it in the courts of a sister state. Kingdon v. Foster, 238 Ga. 37, 230 S.E.2d 855 (1976), cert. denied, 431 U.S. 916, 97 S. Ct. 2179, 53 L. Ed. 2d 226 (1977).

U.S. Const., art. IV, sec. I requires courts of this state to give effect to divorce decree of sister state when properly proved. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Foreign divorce decree obtained by domiciliary of rendering state by constructive service valid.

- A divorce decree granted by a state to one of its domiciliaries is entitled to full faith and credit in another state even though the other spouse is given notice only through constructive service. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Foreign divorce decree invalid as to nonresident on issue of alimony absent personal service.

- Even though a divorce decree is entitled to full faith and credit insofar as it affects marital status, it is ineffective as to a nonresident on the issue of alimony (an in personam judgment) unless there was personal service. Benefield v. Harris, 143 Ga. App. 709, 240 S.E.2d 119 (1977).

Actions on unsatisfied and unmodifiable foreign alimony decrees permitted.

- If a decree for installment payments of alimony or child support is given in a sister state, and the decree constitutes a final and unmodifiable judgment as to amounts due and unpaid under it, the full faith and credit clause requires that Georgia permit actions for the amount due and unpaid up until the time the action is brought. Blue v. Blue, 243 Ga. 22, 252 S.E.2d 452 (1979).

Foreign modified alimony order rendered without personal service unenforceable.

- As a personal judgment for alimony cannot be rendered against a nonresident defendant upon service by publication, and accordingly, an action for modification of alimony cannot be maintained against a nonresident defendant who has not been personally served or has not waived personal service, nor can Mississippi statute which purports to grant court rendering divorce continuing jurisdiction to modify alimony award confer personal jurisdiction over a nonresident defendant who has not consented or subjected herself to the jurisdiction of the Mississippi courts, Mississippi modification order against resident of Georgia who was served by publication and who did not waive personal service was not entitled to full faith and credit in the courts of this state. Veazey v. Veazey, 246 Ga. 376, 271 S.E.2d 449 (1980).

Vested right to due alimony installments entitled to full faith and credit.

- Generally speaking, if a decree is rendered for alimony and is made payable in future installments, the right to such installments becomes absolute and vested upon becoming due and is protected by the full faith and credit clause, provided no modification of the decree has been made prior to the maturity of the installments. Alimony decreed to a spouse in a divorce is as much a debt of record, until the decree has been recalled, as any other judgment for money is. Williamson v. Williamson, 247 Ga. 260, 275 S.E.2d 42, cert. denied, 454 U.S. 1097, 102 S. Ct. 669, 70 L. Ed. 2d 638 (1981).

Modifiable alimony decree unenforceable.

- If the law of the state in which a judgment for future alimony is rendered makes the right to demand and receive such alimony discretionary with the court that rendered the decree, to the extent that no absolute or vested right attaches to receive the installments ordered by the decree to be paid, even though no application to annul or modify the decree in respect of alimony has been made prior to installments falling due, the decree is not protected by the full faith and credit clause. Williamson v. Williamson, 247 Ga. 260, 275 S.E.2d 42, cert. denied, 454 U.S. 1097, 102 S. Ct. 669, 70 L. Ed. 2d 638 (1981).

Decrees subject to further order of court.

- Georgia law distinguishes between an action to enforce an award for support rendered in connection with a divorce decree, although such award is subject to modification, and an action to enforce such award if it is not rendered in connection with a divorce decree and is made subject to "further order of the court," and will not enforce the latter judgment of a sister state. Jagiella v. Jagiella, 647 F.2d 561 (5th Cir. 1981).

Foreign modification of Georgia child support award requires in personam jurisdiction.

- A Kentucky court would be required to have in personam jurisdiction over defendant in order to modify a Georgia award of child support. Earley v. Earley, 165 Ga. App. 483, 300 S.E.2d 814 (1983).

When foreign divorce decree given effect.

- U.S. Const., art. IV, sec. I requires the courts of this state to give effect to a divorce decree of a sister state when properly proved. Tallman v. Tallman, 161 Ga. App. 447, 287 S.E.2d 703 (1982).

Nature of action to enforce alimony decree.

- The action to enforce a decree for alimony of a sister state does not make such action an alimony case; rather it is an action on a debt of record. Tallman v. Tallman, 161 Ga. App. 447, 287 S.E.2d 703 (1982).

Judgments subject to retroactive modification lack requisite finality.

- Final divorce decrees of other states are recognized under the full faith and credit clause. Even those which may be prospectively modified are properly domesticated and enforced in Georgia under principles of comity. Nevertheless, judgments of other states which may be modified retroactively lack the requisite finality to be entitled to full faith and credit. Apple v. Apple, 186 Ga. App. 325, 367 S.E.2d 109 (1988).

Contempt action held unenforceable.

- Although it was not error to domesticate 1975 and 1978 New York divorce and alimony decrees, there was no basis to enforce an action for contempt based on unpaid sums allegedly owed under those decrees, because a reduction of the sums owed to judgment, they were not enforceable in New York. Apple v. Apple, 186 Ga. App. 325, 367 S.E.2d 109 (1988).

Foreign decree awarding custody void for lack of jurisdiction.

- A father's leaving his wife and minor child in Georgia to obtain employment for himself in Michigan, and failing to provide for them, except sending them about $12.00 in two years, held to authorize a finding that the father had voluntarily relinquished parental authority over the child to the mother, thereby rendering the domicile of the child that of its mother, so that a Michigan divorce decree awarding custody of the child to the father was void for lack of jurisdiction, even though the mother filed an answer in the divorce proceeding, asking to be awarded the child; and the court was authorized to determine the habeas corpus case filed by father to regain custody without regard to the foreign judgment, and solely in view of the welfare of the child as an original proposition. Elliott v. Elliott, 181 Ga. 545, 182 S.E. 845 (1935).

Custody decree void for lack of jurisdiction of child.

- On habeas corpus by a father to recover the custody of a minor child living with the mother in Georgia, predicated upon a decree of a Michigan court dissolving the marriage and awarding the child to the father, the full faith and credit clause of the federal Constitution did not preclude the Georgia court from declaring the Michigan decree void for lack of jurisdiction of the child. Elliott v. Elliott, 181 Ga. 545, 182 S.E. 845 (1935).

Foreign custody decree subject to modification in other state for welfare of child.

- A decree of divorce awarding the custody of the children of the parties, rendered by the court of another state having jurisdiction of the subject matter and of the parties, shall be given full effect in this state; but such decree cannot anticipate changes which may occur in the condition of the parents, or in their character and fitness for the care of their children. Accordingly, if, in a proceeding in this state involving the custody of a child, a change is shown in the circumstances of the parties materially affecting the welfare of the child since the foreign decree, the court in the exercise of a sound discretion may protect such welfare accordingly, the same as if there has been such a change since a decree rendered in this state. If the mother and child now reside in this state, and if the father filed his petition in a superior court of this state for injunction against the mother, the court would be authorized, if there was competent evidence of a change in the condition of the parties since the decree materially affecting the child's welfare, to make a new award of custody. Kniepkamp v. Richards, 192 Ga. 509, 16 S.E.2d 24 (1941).

Custody decree rendered without jurisdiction of mother collaterally attackable.

- Although a decree in another state awarding the custody of a child to the father is conclusive as between the parties to the decree and as to the right and fitness for such custody at that time, such a judgment rendered without jurisdiction of the mother may be collaterally attacked without offending the full faith and credit clause of the Constitution of the United States. Carter v. Carter, 201 Ga. 850, 41 S.E.2d 532 (1947).

Divorce decree awarding custody and properly rendered entitled to full faith and credit.

- If the defendant appears and defends, a decree of divorce rendered by a court of another state and regular upon its face is not subject to attack in the courts of this state, and such a decree awarding custody of the children of the parties, rendered by the court of another state having jurisdiction of the subject matter and of the parties, shall be given full effect in this state. Beggs v. Beggs, 208 Ga. 415, 67 S.E.2d 135 (1951).

Valid jurisdiction over parents confers same over minors' custody and support.

- A divorce suit embraces within its scope the care and disposition of minor children, and jurisdiction over the parents confers eo ipso jurisdiction over the minors' custody and support; and if in a foreign court jurisdiction is not claimed by virtue of service by publication on a nonresident, but rests upon an answer and cross-bill filed therein by the nonresident, wherein the custody of the children and alimony for their support is put in issue, such court acquires complete jurisdiction of the marriage status and the custody of the children. Beggs v. Beggs, 208 Ga. 415, 67 S.E.2d 135 (1951).

Foreign custody decree properly obtained entitled to full faith and credit.

- A judgment of a court of competent jurisdiction in another state, awarding the custody of a child to a named person, which judgment is regular on its face and unimpeached for fraud, is conclusive of the status at the time of its rendition, and will be accorded full faith and credit if introduced in proceedings in Georgia for the custody of the child. Peeples v. Newman, 209 Ga. 53, 70 S.E.2d 749 (1952).

Any custody decree subject to modification if welfare of child at issue.

- A judgment awarding the custody of a child, whether rendered by the courts of a sister state or by the courts of Georgia, may be modified upon application if it is shown that there is such a change of conditions since the rendition of the decree as will affect the welfare of the child. Peeples v. Newman, 209 Ga. 53, 70 S.E.2d 749 (1952).

Foreign custody decree unimpeached for fraud entitled to full faith and credit.

- The judgment of a court of competent jurisdiction of a sister state, awarding the custody of a minor child, which is regular on its face and unimpeached for fraud, is entitled to full faith and credit in proceedings for the custody of the child in this state. Belden v. Strickland, 218 Ga. 105, 126 S.E.2d 670 (1962).

Original foreign custody award not res judicata in proceeding for custody where child's welfare at issue.

- An original custody award in a foreign court, under U.S. Const., art. IV, sec. I, is not res judicata as to a subsequent claim of custody based on changes of conditions affecting the child's welfare. Oliver v. Oliver, 225 Ga. 61, 165 S.E.2d 863 (1969).

Duty of courts to modify foreign custody decree if change in conditions adversely affect child.

- Although a decree of a court of a sister state granting custody of a child temporarily for a period of one year must be given effect by the courts of this state under the full faith and credit clause of the United States Constitution, it is nevertheless the duty of the trial courts of this state, if the issues are presented to it, to determine whether there has been a change in conditions subsequent to the entry of the previous decree which adversely affects the welfare of the child, and to determine, based on the present conditions as shown by the evidence, whether the best interests of the child dictate a change in custody. Glover v. Sink, 230 Ga. 81, 195 S.E.2d 443 (1973).

Allowance of evidence of effect of foreign custody decree in rendering state.

- In order to determine the effect of a Maryland decree in regard to child support and custody sought to be enforced by the husband in a divorce action, evidence of the effect of such decree in Maryland should be allowed and the refusal to permit the wife to introduce such evidence is error. Jackson v. Jackson, 231 Ga. 751, 204 S.E.2d 297 (1974).

Foreign custody judgment not incident to divorce decree and without jurisdiction invalid.

- If a foreign court changes or fixes custody of a child, not incident to a divorce decree, without personal jurisdiction over the parties to the action, the judgment so issued need not be recognized under the full faith and credit clause of the Constitution. Schowe v. Amster, 236 Ga. 720, 225 S.E.2d 289 (1976).

Child custody judgment may be entitled to recognition under former Code 1933, Ch. 5, T. 74 (see O.C.G.A. Ch. 9, T. 19) even though such judgment would not be entitled to full faith and credit. Youmans v. Youmans, 247 Ga. 529, 276 S.E.2d 837 (1981).

Prosecution for abandonment.

- Because a North Carolina divorce decree making the divorced wife responsible for the total maintenance of the children would not have barred a North Carolina prosecution of the father for abandonment, the full faith and credit clause did not have the effect of barring a criminal prosecution for abandonment in Georgia. Chapman v. State, 177 Ga. App. 580, 340 S.E.2d 237 (1986).

Supreme Court without jurisdiction where full faith issue not raised in state court.

- Because petitioner failed, in the state proceedings, to raise question of whether the United States Constitution demanded that Georgia give full faith and credit to a Florida custody decree and, the Georgia Supreme Court failed to rule on a federal issue, the United States Supreme Court was without jurisdiction on the petition for certiorari. Webb v. Webb, 451 U.S. 493, 101 S. Ct. 1889, 68 L. Ed. 2d 392 (1981).

ALR.

- Refusal to entertain an action upon a judgment rendered in another state upon a cause of action which it would have been contrary to statute or public policy of the forum to have entertained, 4 A.L.R. 968; 10 A.L.R. 719; 24 A.L.R. 1437.

Pendency of appeal from judgment as affecting right to enforce it in another state, 5 A.L.R. 1269.

Full-faith and credit provision as applying to decree of another state admitting a will to probate, 13 A.L.R. 498.

Refusal to entertain an action upon a judgment rendered in another state on a cause of action which it would have been contrary to public policy of the forum to have entertained, 24 A.L.R. 1437.

Conflict of laws as to contributory negligence, 32 A.L.R. 796.

Inhibition by decree of divorce, or statute of state or country in which it is granted, against remarriage, as affecting a marriage celebrated in another state or country, 32 A.L.R. 1116; 51 A.L.R. 325.

Conclusiveness of decision of sister state on a contested hearing as to its own jurisdiction, 52 A.L.R. 740.

Foreign judgment based upon, or which fails to give effect to, a judgment previously rendered at the forum, or in a third jurisdiction, 53 A.L.R. 1146.

Conclusiveness of officer's return of service of process on which judgment in sister state was rendered, 59 A.L.R. 1398.

Limitation applicable to cause of action created by statute of another state which allows a longer period than the statute of the forum, 68 A.L.R. 217; 146 A.L.R. 1356.

Duty of courts to follow decisions of other states, on questions of common law or unwritten law, in which the cause of action had its situs, 73 A.L.R. 897.

Federal Constitution and conflict of laws as to rights not based on judgments, 74 A.L.R. 710; 100 A.L.R. 1143; 134 A.L.R. 1472.

Duty of court of one state, under the full faith and credit clause of federal Constitution, to recognize and enforce a judgment rendered in another state upon a claim which such court has no jurisdiction to enforce, 76 A.L.R. 1364.

Conflict of laws as to construction and effect of will devising real property, 79 A.L.R. 91.

Extraterritorial recognition and effect on marital status of decree of divorce rendered upon constructive or substituted service, 86 A.L.R. 1329; 143 A.L.R. 1294; 157 A.L.R. 1399; 163 A.L.R. 368.

Conflict of laws as regards survival of cause of action and revival of pending action upon death of party, 87 A.L.R. 852; 42 A.L.R.2d 1170.

Reciprocity as affecting comity, 87 A.L.R. 973.

Conflict of laws as to conditional sale of chattels, 87 A.L.R. 1308; 13 A.L.R.2d 1312.

Assumption of or refusal to assume jurisdiction by court of one state or country, of action on contract involving foreign elements, 87 A.L.R. 1425; 90 A.L.R.2d 1109.

Right to enjoin an action in another state in respect of matters adjudicated in local action or proceeding, 91 A.L.R. 570.

Judgment or order upholding prior judgment in the same state against direct attack upon ground of lack of jurisdiction, as conclusive in another state under the full faith and credit provision or doctrine of res judicata, 104 A.L.R. 1187.

Conflict of laws as to period of limitation to enforce stockholders' statutory liability, 113 A.L.R. 510; 143 A.L.R. 1442.

Full faith and credit provisions as affecting insurance contracts, 114 A.L.R. 250; 119 A.L.R. 483; 173 A.L.R. 1138.

Recognition of foreign marriage as affected by policy in respect of incestuous marriages, 117 A.L.R. 186.

Decree of court of domicil respecting validity or construction of will, or admitting it or denying its admission to probate, as conclusive as regards real estate in another state devised by will, 131 A.L.R. 1023.

Conflict of laws regarding deficiency in respect of debt secured by mortgage or deed of trust, 136 A.L.R. 1057.

Duty of courts of one state to recognize and give effect to decrees of divorce rendered in other states, as affected by constructive service of process or lack of domicil at divorce forum, 143 A.L.R. 1294.

Revival of judgment by constructive service of process upon nonresident, as affected by due process and full faith and credit clauses, 144 A.L.R. 403.

Domestic decree of divorce based upon a finding of invalidity of a previous divorce in another state, as estopping party to the domestic suit to assert, in a subsequent litigation, the validity of the divorce decree in the other state, 150 A.L.R. 465.

Recognition of status created by foreign adoption or legitimation for purposes of testate or intestate distribution of decedent's estate in a jurisdiction in which such status could not have been created even in the case of one domiciled there, 153 A.L.R. 199.

Decree for alimony in installments as within full faith and credit provision, 157 A.L.R. 170.

Duty to recognize and give effect to decrees of divorce rendered in other states, or in foreign country, as affected by constructive service of process or lack of domicil at divorce forum, 157 A.L.R. 1399.

Extraterritorial effect of provision in decree of divorce as to custody of child, 160 A.L.R. 400.

Judgment for defendant based on the statute of limitations as bar to maintenance of action in another state, 164 A.L.R. 693.

Right to maintain action or proceeding in one state or country to collect or enforce tax due to another state or country or political subdivision thereof, 165 A.L.R. 796.

Estoppel to assert invalidity of decree of divorce for lack of domicil at the divorce forum or failure to obtain jurisdiction of person, 175 A.L.R. 538.

Recognition as to marital status of foreign divorce decree attacked on ground of lack of domicil, since Williams decision, 1 A.L.R.2d 1385, 28 A.L.R.2d 1303.

Consent decree as affecting title to real estate in another state, 2 A.L.R.2d 1188.

Denial of divorce in sister state or foreign country as res judicata in another suit for divorce between the same parties, 4 A.L.R.2d 107.

Inclusion in domestic judgment or record, in action upon a judgment of a sister state, of findings respecting the cause of action on which the judgment in the sister state was rendered, 10 A.L.R.2d 435.

Foreign divorce decree as subject to attack by spouse in state of which neither spouse is resident, 12 A.L.R.2d 382.

Standing of strangers to divorce proceeding to attack validity of divorce decree, 12 A.L.R.2d 717.

Foreign filiation or support order in bastardy proceedings, requiring periodic payments, as extraterritorially enforceable, 16 A.L.R.2d 1098.

Validity and enforceability of judgment entered in sister state under a warrant of attorney to confess judgment, 39 A.L.R.2d 1232.

Enforceability in another jurisdiction of personal liability of stockholders for debts of corporation whose organization is incomplete or defective, 42 A.L.R.2d 659.

Enforceability of provision in agreement for attorney's fees, valid in state of its execution or performance, but invalid under law of forum, 54 A.L.R.2d 1053.

Injunction against suit in another state or country for divorce or separation, 54 A.L.R.2d 1240.

Fraud as defense to action on judgment of sister state, 55 A.L.R.2d 673.

Conflict of laws as to attorneys' liens, 59 A.L.R.2d 564.

Conflict of laws as to interest recoverable as part of the damages in a tort action, 68 A.L.R.2d 1337.

What law governs effect of release of one tort-feasor upon liability of another tort-feasor, 69 A.L.R.2d 1034.

Doctrine of forum non conveniens: assumption or denial of jurisdiction of contract action involving foreign elements, 90 A.L.R.2d 1109.

Conflict of laws as to right of action between husband and wife or parent and child, 96 A.L.R.2d 973.

Law governing assignment of wages or salary, 1 A.L.R.3d 927.

Judgment subject to appeal as entitled to full faith and credit, 2 A.L.R.3d 1384.

Power of divorce court to deal with real property located in other state, 34 A.L.R.3d 962.

Conflict of laws as to presumptions and burden of proof concerning facts of civil case, 35 A.L.R.3d 289.

Extraterritorial effect of valid award of custody of child of divorced parents, in absence of substantial change in circumstances, 35 A.L.R.3d 520.

Requirement of full faith and credit to foreign judgment for punitive damages, 44 A.L.R.3d 960.

Conflict of laws as to right of action for loss of consortium, 46 A.L.R.3d 880.

Disbarment or suspension of attorney in one state as affecting right to continue practice in another state, 81 A.L.R.3d 1281.

Extraterritorial application of statute permitting injured person to maintain direct action against tort-feasor's automobile liability insurer, 83 A.L.R.3d 338.

Choice of law as to application of comparative negligence doctrine, 86 A.L.R.3d 1206.

Full faith and credit "last-in-time" rule as applicable to sister state divorce or custody judgment which is inconsistent with the forum state's earlier judgment, 36 A.L.R.5th 527.