Harris v. Balk
United States Supreme Court
198 U.S. 215 (1905)
Balk (plaintiff), a North Carolina resident, was owed $180 by fellow North Carolina resident Harris (defendant); separately, Balk owed $344 to Epstein, a Maryland resident. While briefly in Baltimore, Harris was served with Epstein's writ of attachment targeting the debt Harris owed Balk, and Harris ultimately consented to the Maryland attachment judgment. Balk then sued Harris in North Carolina for the same $180, and Harris argued he had already effectively paid the debt through the Maryland judgment, which North Carolina should recognize under full faith and credit; the North Carolina courts disagreed, reasoning Harris's presence in Maryland had been merely temporary.
Whether a garnishment or attachment judgment rendered in one state is entitled to full faith and credit in another state where the underlying debtor and creditor both reside.