Watkins v. Conway
United States Supreme Court
385 U.S. 188 (1966)
Watkins (plaintiff) obtained a tort judgment against Conway (defendant) in Florida, which had a 20-year enforcement limitations period, but waited more than five years before suing on that judgment in Georgia, whose own statute barred suits on foreign judgments filed more than five years after entry or revival; Watkins never revived the Florida judgment before filing in Georgia. The Georgia courts held the suit time-barred under the state's five-year rule, and Watkins argued that rule violated the Full Faith and Credit Clause.
Whether the Full Faith and Credit Clause requires a forum state to enforce a foreign judgment that is no longer being timely pursued according to a reasonable procedural limitation, even though the judgment remains valid and enforceable in the state where it was originally entered.