Smith v. Superior Court

In this case, we are called upon to decide whether the full faith and credit clause of the United States Constitution requires California courts to enforce a permanent injunction entered by a court in another state in unrelated proceedings which adversely affects petitioners’ discovery rights. We answer in the negative. We hold that because the out-of-state injunction was obtained in a proceeding to which petitioners were not parties, and it violates fundamental California public policy, the full faith and credit clause does not compel its recognition in our courts.

Relevant Facts

1. The accidents.

On November 29, 1991, petitioner Dora A. Smith, her husband and two children were involved in a multiple vehicle collision. The 1980 Chevrolet Monza vehicle in which they were traveling burst into flames. Although Smith was severely injured, she survived the accident. However, her husband and two children were unable to exit the Monza and suffered fatal bums. Smith sued General Motors Corporation (GM), setting forth a cause of action for product liability alleging the Monza’s fuel tank system had been defectively designed and manufactured.

On May 8,1992, petitioners Robert…