Baker v. General Motors Corporation
United States Supreme Court
522 U.S. 222 (1998)
Former GM (defendant) engineer Ronald Elwell later gave deposition testimony in a products-liability case that was harshly critical of GM's fuel-system safety, prompting GM to obtain a Michigan injunction (later made permanent by settlement) barring Elwell from consulting or testifying about GM's confidential information, though the settlement allowed him to testify if compelled by a tribunal. When the Bakers (plaintiffs), suing GM in Missouri over a fatal fuel-fed fire, subpoenaed Elwell, the Missouri trial court allowed the testimony, finding blocking it would violate Missouri public policy and that the injunction could be modified. Elwell's testimony helped the Bakers win $11.3 million, but the appellate court reversed, holding the Full Faith and Credit Clause required Missouri to honor the Michigan injunction; the Supreme Court granted certiorari.
Whether the Full Faith and Credit Clause requires a state court to honor another state's injunction to the extent that injunction purports to control witness testimony and evidentiary matters in litigation pending in the second state, over parties and issues outside the first state's jurisdiction.