High-Stakes Legal Poker: Unveiling the Power of the Full Faith and Credit Clause

Imagine you’re in a nail-biting poker game, where every decision could tip the balance between winning and losing. Suddenly, one player reveals a Royal Flush—an unbeatable combination. This tension-filled scene mirrors the legal drama between Greenfield Advisors LLC, a consulting firm from Seattle, and Salas & Co., LC, over a significant unpaid debt. In the legal world, invoking the Full Faith and Credit Clause was Greenfield’s equivalent of a Royal Flush, a powerful play with wide-ranging implications. This legal gambit’s riveting repercussions underline the robust judicial principle of full faith and credit. In the case, the Louisiana Fourth Circuit Court of Appeal affirmed the State District Court’s decision that the judgments against the Appellants were entitled to full faith and credit.

To explain, Greenfield Advisors (“Greenfield”), who were owed a hefty sum of around $700,000 by Salas & Co. (“Salas”), took the dispute to court. Salas, who had hired Greenfield for various legal consulting services, had only paid a fraction of the amount. Greenfield filed a lawsuit, and the legal wrangling kicked off in earnest. The case found itself in the Federal District Court in Washington after Salas requested a transfer. With the dispute in arbitration, Greenfield came out on top, awarded $331,316.48, along with a generous interest rate. The battle, however, was far from over.

In the Louisiana court, Salas argued that the Federal District Court overstepped its jurisdiction, suggesting that the Louisiana court should examine this issue before acknowledging the federal judiciary. The Full Faith and Credit Clause, a crucial element of the U.S. Constitution, became the focal point. Under Louisiana law, any judgment, decree, or order of a court of the United States or any other court is entitled to full faith and credit in this state. LA R.S. 13:4241. A judgment delivered by a court in one state should be respected and enforced by all other states.

Under Louisiana law, the res judicata doctrine prohibits subsequent actions by the same parties arising out of the same transaction or occurrence that is the subject matter of the first litigation. La. R.S. 13:4231. Greenfield’s victory in Washington had to carry weight in Louisiana for them to collect their dues. The Court of Appeal saw it the same way as the State District Court. The State District Court recognized the issue had been litigated and correctly found that those decisions are res judicata. They affirmed that the matter of jurisdiction had been comprehensively litigated and decided by the Federal District Court—meaning it couldn’t be rehashed in the Louisiana court. Schultz v. Doyle. 

This high-stakes legal drama underscored the importance of the Full Faith and Credit Clause and the weight of court decisions, even across state lines. It also highlighted the importance of a good lawyer or an excellent attorney who can navigate these complicated interstate legal waters. The difference of having their expertise can turn a tense legal poker game into a winning hand.

Additional Sources: Greenfield Advisors LLC v. Salas.

Written by Brian Nguyen

Additional Berniard Law Firm Article on Res Judicata: Ascension Parish Plaintiff has Lawsuit Barred due to Res Judicata